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Privacy Policy

Last updated: May 27, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to Roomster, the software program provided by the Company.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to ROOMSTER CORP., 3921 Alton Rd, #280, Miami Beach, FL 33140, USA.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Florida, United States

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

GDPR refers to EU General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Service refers to the Application or the Website or both.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Roomster, accessible from https://roomster.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Email Address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code, City

Usage Data

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

· Information regarding your location

· Information from your Device's phone book (contacts list)

· Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Privacy Policies website article.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

We may share Your personal information in the following situations:

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

AWS Simple Email Service

Their Privacy Policy can be viewed at https://aws.amazon.com/privacy/

Oracle Email Delivery

Their Privacy Policy can be viewed at https://www.oracle.com/legal/privacy/privacy-policy/

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Amazon

Their Privacy Policy can be viewed at https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/us/legalhub/paypal/privacy-full

Worldpay

Their Privacy Policy can be viewed at https://privacy.worldpay.com/policies

AIB

Their Privacy Policy can be viewed at https://aib.ie/Privacy-Statement

  

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Usage, Performance and Miscellaneous

We may use third-party Service Providers to maintain and improve our Service.

Invisible reCAPTCHA

We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from You and from Your Device for security purposes.

The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No other than “sex” which data we do collect.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

We cannot respond to Your request or provide You with the required information if We cannot:

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:


Mexico Privacy Notice

Updated: April 2025

In compliance with the duty to safeguard information and personal data, and based on the provisions of articles 3, section I, 8, 12, 15, 16, and other related articles of the Federal Law on Protection of Personal Data Held by Private Parties, Roomster, Corp., trading under the name Roomster, provides this Privacy Notice.

1. INTRODUCTION

1.1 What does this Privacy Notice regulate?

This Privacy Notice (from now on the “Notice”) reflects our commitment to protecting the privacy of individuals regarding their personal data.

This Notice applies to individuals who visit our website, register to request information, business contact, or demonstrate the products we market. It also applies to individuals using our Services (as defined below) by accessing Roomster.

1.2 What is the purpose?

To provide the necessary information to ensure the protection of personal data. We explain what data we collect, for what purposes, and the resources available to you.

Regarding our Services, we clarify that it is not possible to provide the Service without access to certain personal data, as detailed below.

2. INFORMATION ABOUT ROOMSTER AND ITS ROLE REGARDING PERSONAL DATA., trading under the name "Roomster," is responsible for processing the personal data of website visitors and Clients (as defined below).

3. PURPOSE: Why do we process your data?

To manage the web browsing experience.

To handle any type of request, suggestion, or inquiry about our services made by interested parties.

Commercial communications: Processing your data to inform you about activities, articles of interest, and general information about our services via email.

To fulfill the Service you have contracted (if you are a "Client").

To process your payment request (if you are an “End User”).

4. MECHANISM: How do we collect personal data?

Roomster may collect personal data in the following cases:

(a) When browsing the Website;

(b) When contracting and/or using the Services;

(c) When personal data was received by other legitimate sources by applicable regulations.

5. PURPOSE: What personal data is processed?

If you are browsing our Website

We request and may collect personal information about visitors when they submit forms from our Website, such as their name, address, telephone number, and email address, as well as certain related information such as their company name, Website, and job title.

Roomster may use cookies and other information-gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks that the visitor uses to access our Website, and other information related to your interactions with our Website.

In addition, it should be noted that it is possible to configure the browser used to be notified of the receipt of cookies by changing the preferences from the privacy section and/or preventing their installation, which will implement these changes from the browser you log in. That is, if you log in from another browser, you will have to perform the same steps, as we will give you our cookie warning again.

If you use our Services:

When contracting and/or using our Services, we may collect the following data:

Individuals: Full name, type and number of ID (e.g., cédula, DNI, or another, depending on the country of issuance), and email.

.

6. STORAGE

6.1 How long will your data be kept?

Data will be retained for as long as necessary to fulfill the purpose of processing, according to the purposes mentioned above, or if legal obligations dictate its retention.

6.2 Who do we share your personal data with?

Your personal data will not be shared with third parties unless it is necessary for the development and execution of the purposes of processing, in the following cases:

With our service providers related to communications, with whom the CONTROLLER has signed confidentiality agreements as required by current privacy regulations.

With Roomster group entities for the management and administration of the commercial agreement.

With auditors, only to fulfill Roomster's legal and regulatory obligations.

With judicial or administrative authorities upon written request.

7. RIGHTS: What are they and how can you exercise them?

7.1 What are your rights?

Known as “ARCO” rights: Access, Rectification, Cancellation, and Opposition.

You have the right to:

Access your personal data in our possession.

Rectify incorrect or outdated data.

Request the deletion of data when you consider it unnecessary for the stated purposes.

Object to the use of your data for specific purposes.

7.2 How can you exercise them?

You can send a written request to the following email: legal@roomster.com

By visiting this page on our website: https://roomster.com/support

Responses will be sent to the email provided by the requester within 20 business days.

7.3 Options to limit the use or disclosure of personal data:

If you wish to revoke the consent granted for the processing of your personal data or limit its disclosure, you can submit your request via the following email: datospersonales@Roomster.com.

Responses will be sent within 20 business days to the email address provided by the requester.

8. MANDATORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED

Users, by checking the appropriate boxes and entering data in the fields marked with an asterisk (*) on contact forms or download forms, expressly and freely accept that their data is necessary for the service request. Providing data in the remaining fields is voluntary. End Users guarantee that the personal data provided to the CONTROLLER is truthful and are responsible for informing any changes.

The CONTROLLER informs that all data requested through the website is necessary for optimal service provision. If all data is not provided, the information and services may not fully meet your needs.

9. SECURITY MEASURES

In accordance with current personal data protection regulations, the CONTROLLER complies with all legal and regulatory provisions, specifically those described in article 10 of Law 18.331, ensuring that data is processed lawfully, fairly, and transparently in relation to the data subject, and is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

The CONTROLLER guarantees that appropriate technical and organizational policies have been implemented to ensure the security measures required by law, aiming to protect USERS' rights and freedoms, and has communicated adequate information to enable them to exercise their rights.

For more information on privacy guarantees, you can contact the CONTROLLER at datospersonales@Roomster.com.

10. INTERNATIONAL TRANSFER OF DATA

Under the Federal Law on Protection of Personal Data Held by Private Parties and its regulations, we inform you that your personal data may be transferred and processed outside of Mexico by third parties, such as affiliates, subsidiaries, technology service providers, or business partners, to fulfill the purposes described in this Privacy Notice.

Transfers will only be made to countries with equivalent or superior personal data protection levels as established by Mexican legislation or countries with adequate mechanisms to guarantee data protection.

If it is necessary to transfer your personal data to a country that does not meet these conditions, we will request your express prior consent unless the transfer is required to fulfill a legal or contractual obligation.

By accepting this Privacy Notice, you expressly consent to the transfer of your personal data under the terms and conditions set out in this document, including international transfers, provided the necessary security measures are in place to protect your data. If you do not express opposition to such transfers, we will assume that consent has been granted.

11. DEFINITIONS

Client

It is the legal entity that contracted with Roomster for any of the Services.

Contact

Whoever processes personal data on behalf of the data controller.

Responsible

Who decides on the processing of personal data.

Services

Services available from Roomster.

Website

It shall refer collectively to "https://Roomster.com" as well as to other websites that Roomster operates that relate to this Policy, such as promotional landings, forums, or more specific sites.

End User

It is the natural or legal person who contracts products or services directly to the Client, and who consequently uses any of the Services.

12. CHANGES TO THIS POLICY AND COMPLIANCE

Roomster may modify this Notice at its sole discretion. If modified, the new version will be published on the Website. Your continued use of our Services and/or browsing of the Website after such changes will constitute acceptance of the new terms.

IMPORTANT: If you do not agree with this Notice, you must stop using our services and/or accessing the Website.


Canadian Privacy Policy

Privacy Statement

This policy deals only with personal information handled by the Roomster, Inc. Personal information is information about an identifiable individual, excluding business contact information. The following explains how Roomster handles personal information. Roomster reserves the right to change this policy and it may be updated periodically. These changes may affect the use of personal information. Accordingly, please check for changes regularly.

Accountability

Roomster is accountable for all personal information under its control. Roomster’s Privacy Officer is Charles S Brofman Esq. our Counsel who is designated as responsible for Roomster privacy policy. The Privacy Officer can be reached by:

Email: legal@roomster.com

Telephone: +1 917 747 7100

Any questions about Roomster’s handling of personal information should be directed to the Privacy Officer. In cases where the question concerns an access request, individuals must follow the request process described under Accuracy of and Access to Personal Information Collected.

Purposes for Collection, Use and Disclosure of Personal Information

The purpose for which Roomster collects personal information will be identified at or before the time the information is collected. Personal information may be collected for such purposes as: processing and administering the Services or other purposes as necessary.

Roomster will not use personal information for any other purpose than identified at or before the time of collection.

Consent

Roomster seeks consent for all personal information it collects, uses and discloses through information provided to individuals prior to collection, or at the time of collection.

If information is voluntarily provided, this is interpreted as consent to the collection, use and disclosure of personally identifiable information as described in this Privacy Policy. As required by the CSA Model Code, Roomster will not use personal information for any purpose other than that for which consent has been provided. Should Roomster require use of personal information for a new purpose, consent will be sought for that new use.

Limits for Collecting, Using, Disclosing and Keeping Personal Information

Roomster does not collect, use or disclose personal information of individuals except when individuals give consent and provide the information on a voluntary basis. There may be occasions where more specific personal information is necessary for Roomster to proceed with a request for information, or provide a product or service. In such cases, Roomster will describe the information required. In all such cases, Roomster limits the amount and type of information collected to only the personal information that is required to provide the individual with the requested information, product, or service. Roomster collects only information that is voluntarily provided by the individual and undertakes that such information will be kept strictly confidential.

Roomster may disclose personal information collected by it without the knowledge or consent of the individual, for example to its lawyers; for purposes relating to an investigation under, the enforcement of or the administration of a law or where required by law to disclose the information. Roomster will not use or disclose personal information without the knowledge or consent of the individual except as authorized by applicable law.

Roomster does not sell or trade any personal information with third parties. Information may be transferred to third parties where information processing is outsourced by Roomster in the course of its activities or administrative procedures in specific cases. Some personal information collected by Roomster is transferred to our service providers for processing and storage. Some of our service providers are located outside of Canada and accordingly your data may be processed and stored outside of Canada, and may be subject to the laws of the jurisdiction in which it is processed or stored. Roomster requires service providers to respect this Privacy Policy. Service providers are restricted from using or disclosing personal information transferred to them for any purpose other than the provision of services to Roomster.

Any personal information that Roomster retains is kept in such a manner as to ensure its security and confidentiality at all times.

Accuracy of and Access to Personal Information Collected

Roomster makes every effort to keep personal information as accurate, complete, current and relevant as necessary for the identified purposes. Roomster does not routinely update personal information.

Roomster makes readily available to individuals its Privacy Policy and related procedures for managing personal information. Customer access to the Privacy Policy and related procedures is provided on the Roomster, Inc.’s website and in written form. Any questions about the handling of personal information by Roomster can be raised with the Privacy Officer.

At the written request of an individual, he or she may view or edit their personal information as collected by Roomster. Roomster will inform them of what personal information it has about the individual, what it is being used for and, in cases where it has been disclosed, to whom it has been disclosed. There may be exceptional circumstances as provided by the CSA Model Code under which Roomster may not be able to give an individual access to personal information held about them by Roomster. In this case Roomster will explain the reason for this lack of access, as provided by the CSA Model Code.

To make a request, please send a letter, email or fax addressed to our Privacy Officer at the address indicated above. In any written request, please include the following information:

Name

Contact details

Nature of the request, for example:

view and/or edit information

inquire regarding use and/or disclosure

If an inquiry concerns a specific transaction, please indicate the date of the transaction, and provide a receipt number if applicable.

Roomster will reply to requests in no later than thirty days after receipt of the request, or if it is not able to respond within this time period, a notice of extension will be sent.

Questions

Any questions or comments about the Roomster Corp.’s handling of personal information should be directed to the Privacy Officer.

Use of the Roomster Corp. Website and App

Roomster believes that online privacy is important to the success of the Internet and electronic commerce in general and is strongly committed to each visitor’s right to privacy. This statement sets forth the Privacy Policy for its website located at roomster.com and describes the practices that Roomster follows in respect to the privacy of the users of this site. By accessing and using materials from this Website or sending or posting materials to it, you (the “user”) agrees to the terms of this privacy commitment and to our practices to collect, use or disclose personal information.

This Privacy Statement may be updated periodically to reflect enhancements to Roomster Website that may affect the use of personal information. Accordingly, please check back periodically.

Information on This Website

Information which includes all facts, data and other information, collectively the “Information” in the pages of this website is of a general nature, is intended only for informational purposes, is subject to change without notice, and is not intended to be relied on by visitors as binding legal advice on any particular matter.

Individual information provided to Roomster to gain access to any feature of this website will not be sold or made available to any third party, except where information processing is outsourced by Roomster in the course of its regular administrative procedures.

Roomster reserves the right to perform statistical analyses of aggregated user behavior and characteristics, in order to measure interest in and use of the various sections of its site so as to improve design and navigation and to gather information for marketing purposes. Only aggregated data from these analyses, not individual data, will be used for this purpose.

“Cookies” are not attached to Roomster website. A “cookie” is a piece of data that is stored on the hard drive of a computer that contains information about use of the website. Other Websites may contain “cookies” that accumulate information about website use, for example a record of the websites that an individual has visited.

Accuracy of the Information on This Website

The information is believed to be accurate, complete and current when posted, but Roomster cannot guarantee that it will remain accurate or complete or that it will be current at all times.

Roomster is not responsible for direct, indirect, special or consequential damages, regardless of the cause, arising out the use of this website.

Accuracy of Information on Linked Websites

Through the links to other sites found on Roomster’s website, the user may enter domains that are beyond the boundaries of Roomster and, once there, Roomster is not responsible for the privacy practices or the content of these websites. Roomster has no control over the accuracy, completeness or relevance of the information on these sites and provides links to these sites solely for the information and convenience of visitors to our website.

Copying Information from This Website

The information on Roomster website may be used or copied provided that it is used or copied accurately, or is used in its entirety and/or that the source of the information is clearly identified. Only a member of Roomster may use the information for commercial purposes. Roomster is not responsible for the way in which the information may be used or copied. Roomster reserves the right to change, delete or add information at any time.


Australian Privacy Policy

Roomster Corp. is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained in many ways including via our website www.roomster.com, from cookies and from third parties. We don’t guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained

• For a secondary purpose that is directly related to the primary purpose

• With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and

• Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Roomster will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

529 West 41st Street, Miami Beach, Florida 33140 #280

Email: legal@roomster.com

Phone +1 786 400 1364


New Zealand Privacy Policy

You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. If you’d like to ask for a copy of your information, or to have it corrected, please contact us at by visiting this page on our website: https://roomster.com/support