Legal

Terms of Service & Privacy Policy

How eROAM.ai — operated under Triple Data Network & Telecommunications LTD (TDNT) — provides your global eSIM connectivity, and how we collect, use, and protect your personal data under GDPR and Cyprus law.

Effective: July 21, 2026 Updated: July 21, 2026 Entity: eROAM.ai, operated under TDNT LTD
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Part I

Terms of Service

1

General Overview & Agreement

These Terms of Service ("Terms") govern your access to and use of the digital eSIM provisioning services, global data roaming bundles, mobile application features, and telecommunication integrations provided by eROAM.ai ("eROAM.ai," "we," "us," or "our"), operated under Triple Data Network & Telecommunications LTD (TDNT).

By purchasing an eSIM, activating a data bundle, using our mobile app, or accessing our platform at eroam.ai, you agree to be bound by these Terms and our Privacy Policy.

2

Operational Framework & Ecosystem Integration

  • Service Scope: eROAM.ai specializes in global eSIM profiles, digital roaming bundles, and automated connectivity solutions for international travellers and enterprise users.
  • Ecosystem Integration: eROAM.ai operates directly under TDNT LTD and integrates with TDNT's underlying carrier infrastructure and CPaaS platforms (such as ePOC) to deliver seamless mobile data routing.
  • Device Compatibility & Fair Use: Users are responsible for ensuring their mobile devices are carrier-unlocked and eSIM compatible prior to purchase. Network usage must comply with fair usage policies and applicable telecommunications regulations.
3

eSIM Purchases, Billing, and Refunds

  • Pricing & Currency: Data bundles and roaming plans are priced in Euros (€) or designated transactional currencies, including applicable Cyprus VAT and telecommunication charges.
  • Activation & Validity: Data bundle validity periods begin upon initial network attach/activation or as specified in the plan details.
  • Refunds: Due to the digital nature of eSIM profile delivery, refunds are generally limited to technical provisioning failures verified prior to profile installation or data consumption.
4

Network Quality & Limitation of Liability

Global roaming depends on partner cellular networks across destination countries. While eROAM.ai strives for high-speed coverage, service quality may vary based on local carrier infrastructure, geographical terrain, or network congestion. To the extent permitted by Cyprus law, eROAM.ai and TDNT LTD are not liable for temporary roaming disruptions beyond our reasonable control.

Part II

Privacy Policy — GDPR & Cyprus Law

1

Data Controller Information

Triple Data Network & Telecommunications LTD (TDNT LTD), operating eROAM.ai, is the official Data Controller responsible for processing your personal data under the EU GDPR, Cyprus Law 125(I)/2018, and electronic communications privacy laws.

Controller

eROAM.ai (operated under TDNT LTD)

Registered Office

Cyprus

Supervisory Authority

OCPDP, Cyprus

2

Scope & Categories of Personal Data Collected

We process personal data essential for delivering digital eSIM profiles and roaming connectivity:

  • Identity & Account Data: Name, email address, phone number, and ID/passport details (when mandatory for regional telecom identity verification/KYC).
  • Service & eSIM Usage Data: eSIM activation keys (LPA/QR codes), ICCID/IMSI identifiers, bundle purchase records, data consumption logs, and connectivity timestamps.
  • Financial Data: Invoices, transaction reference IDs, billing country, and payment card details (processed securely via PCI-DSS gateways).
  • Technical & Network Data: Device model, OS version, IP address, device location/MCC-MNC routing metadata, and app analytics.
  • Special Category Data: Processed strictly when required by law (e.g., emergency service routing or regulatory compliance).
3

Purpose of Processing & Legal Basis

We process personal data under the following GDPR Article 6 legal grounds:

Swipe to see all columns

Purpose Personal Data Category Legal Basis (GDPR Art. 6)
Provisioning eSIMs, activating data bundles, and managing user accounts Identity, Service, Financial, Technical Contractual Necessity — 6(1)(b)
Synchronizing network connectivity and CPaaS routing with TDNT LTD and ePOC Service, Technical Contractual Necessity & Legitimate Interest — 6(1)(b)/(f)
Telecommunications legal compliance, KYC obligations, tax reporting, and lawful interception Identity, Service, Financial Legal Obligation — 6(1)(c)
App notifications, promotional updates, and customer survey invitations Identity, Technical Consent — 6(1)(a)
Preventing SIM fraud, optimizing data routing, and securing mobile applications Technical, Service Legitimate Interest — 6(1)(f)
4

Children's Personal Data

Under Article 8 of Cyprus Law 125(I)/2018, the legal age for digital consent for information society services is 14 years. eROAM.ai does not knowingly collect or process personal data from children under 14 without verifiable parent or guardian authorization.

5

Third-Party Sharing & Cross-Border Transfers

A. Ecosystem Integration
eROAM.ai shares operational telecom data with parent entity TDNT LTD and integrated platforms like ePOC to complete profile downloads and network authentication.

B. Global Carrier Partners & Vendors
We transfer necessary profile identifiers to international mobile network operators (MNOs/MVNOs) and secure cloud hosting providers under Data Processing Agreements (DPAs) to enable international data roaming.

C. Cross-Border Transfers & Special Approvals
Data transferred outside the European Economic Area (EEA) is protected via standard mechanisms like Standard Contractual Clauses (SCCs) or the EU–U.S. Data Privacy Framework.

Cyprus-specific requirement: Exporting Special Category Data outside the EEA requires prior notification or authorization from the Cyprus Commissioner for Personal Data Protection (OCPDP).
6

Retention Schedule

Data is stored in compliance with Cyprus legal and telecommunications mandates:

  • eSIM & Traffic Metadata Records: Minimum 6 months as required under Cyprus telecommunications retention law (or longer if required for billing disputes).
  • Client Contracts & Account Data: Duration of account active status + 6 years.
  • Financial & Tax Data: Minimum 6 years from the end of the tax year under Cyprus tax legislation.
  • Marketing Data: Retained until consent is withdrawn or unsubscribed.
7

Your Data Protection Rights

Under GDPR and Cyprus Law 125(I)/2018, you possess the following rights:

Right to Access

Request a copy of personal data processed by eROAM.ai.

Right to Rectification

Correct inaccurate or incomplete account details.

Right to Erasure

Request data deletion, subject to telecom retention laws.

Right to Restriction

Limit data processing under specific legal conditions.

Right to Data Portability

Export account and transaction records in standard formats.

Right to Object

Object to processing based on legitimate interests or direct marketing.

Right to Withdraw Consent

Revoke consent for optional services at any time.

8

Cookies and Tracking Technologies

  • Essential Cookies & Tokens: Required for secure mobile app sessions, web portal login, and checkout procedures.
  • Analytics Cookies: Enabled only with explicit user consent to analyze app performance and improve roaming features.
9

Security Measures

eROAM.ai maintains robust security safeguards (GDPR Art. 32):

  • Encryption: End-to-end encryption for eSIM SM-DP+ provisioning workflows, TLS encryption for API calls, and AES-256 for database storage.
  • Access Controls: Role-based access controls for operational staff and secure API token authentication.
  • Incident Management: Incident response protocol with 72-hour notification procedures to the OCPDP for data breaches.
11

Amendments

eROAM.ai reserves the right to update this policy to reflect operational, legal, or technical changes. Material updates will be communicated via email, app notifications, or website announcements prior to taking effect.

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