Legal
Data Processing Agreement
Effective: 4 November 2026
This Data Processing Agreement (DPA) is between RoamGuard Global Ltd, a company registered in England and Wales with company number 17263828, trading as RoamGuard (RoamGuard, the Processor), and the business that has created a RoamGuard account and accepted the Terms of Service (the Customer, the Controller).
It forms part of the Terms of Service and applies automatically whenever RoamGuard processes personal data on the Customer's behalf in providing the RoamGuard service (the Service). A countersigned copy is available on request from support@roamguard.co.uk.
1. Definitions
Terms such as personal data, processing, controller, processor, data subject and personal data breach have the meanings given in the UK GDPR and the Data Protection Act 2018 (Data Protection Law). Sub-processor means a third party engaged by RoamGuard to process Customer Personal Data. Customer Personal Data means the personal data described in Annex 1.
2. Roles and instructions
2.1 The Customer is the controller and RoamGuard is the processor of Customer Personal Data.
2.2 RoamGuard will process Customer Personal Data only on the Customer's documented instructions, including those given through the Service's settings and features, unless UK law requires otherwise. In that case RoamGuard will tell the Customer before processing, unless the law prohibits it.
2.3 RoamGuard will tell the Customer promptly if it believes an instruction breaches Data Protection Law.
2.4 The Customer is responsible for having a lawful basis to provide Customer Personal Data, for its notices to travellers, and for deciding which documents to request, including any special category data such as medical certificates.
3. Confidentiality
RoamGuard will ensure that everyone it authorises to process Customer Personal Data is bound by a duty of confidentiality.
4. Security
RoamGuard will implement appropriate technical and organisational measures under Article 32 UK GDPR, including at least those in Annex 2. RoamGuard may update them provided the overall level of protection is not reduced.
5. Sub-processors
5.1 The Customer gives general authorisation for RoamGuard to use the Sub-processors listed in Annex 3.
5.2 RoamGuard will give the Customer at least 30 days' notice of a new Sub-processor that will process Customer Personal Data, by email or on the RoamGuard security page. The Customer may object on reasonable data protection grounds. If the parties cannot resolve the objection, the Customer may end the affected part of the Service.
5.3 RoamGuard will put in place a written contract with each Sub-processor that imposes data protection obligations no less protective than this DPA. RoamGuard remains responsible for its Sub-processors' performance.
6. International transfers
RoamGuard stores Customer Personal Data in the United Kingdom (London). Where a Sub-processor processes Customer Personal Data outside the UK, RoamGuard will ensure a valid transfer mechanism applies, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
7. Assistance
7.1 RoamGuard will, taking into account the nature of the processing, help the Customer respond to requests from data subjects exercising their rights. RoamGuard will pass any request it receives directly to the Customer and will not respond itself unless instructed.
7.2 RoamGuard will give reasonable help with the Customer's obligations under Articles 32 to 36 UK GDPR (security, breach notification, data protection impact assessments and prior consultation).
8. Personal data breaches
RoamGuard will notify the Customer without undue delay, and in any event within 48 hours, after becoming aware of a personal data breach affecting Customer Personal Data. The notice will include the information the Customer reasonably needs to meet its own reporting duties, provided in stages if necessary.
9. Deletion and return
9.1 During the Service, RoamGuard deletes Customer Personal Data in line with the retention schedule in Annex 4.
9.2 When the Service ends, RoamGuard will, at the Customer's choice, return or delete Customer Personal Data within 30 days, unless UK law requires it to be kept. Records RoamGuard holds as controller, such as invoices, are not covered by this clause.
10. Audits and information
RoamGuard will make available the information reasonably necessary to demonstrate compliance with this DPA, and will allow for and contribute to audits by the Customer or its appointed auditor. Audits must have reasonable notice, take place during business hours, happen no more than once a year unless a breach has occurred, and are subject to confidentiality. Each party bears its own audit costs, unless the audit reveals a material breach of this DPA by RoamGuard, in which case RoamGuard bears the Customer's reasonable audit costs.
11. Liability and term
Liability under this DPA is subject to the limitations in the RoamGuard Terms of Service. This DPA lasts as long as RoamGuard processes Customer Personal Data for the Customer. If this DPA and the Terms of Service conflict on the processing of Customer Personal Data, this DPA prevails.
12. Governing law
This DPA is governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.
Annex 1: Details of the processing
| Details | |
|---|---|
| Subject matter | Preparing travellers for international work deployments: readiness checks, document collection and review, specialist referrals, connectivity and arrival confirmation. |
| Duration | The term of the Service, plus the retention periods in Annex 4. |
| Nature and purpose | Collecting, storing, organising, reviewing, sharing with nominated Sub-processors, and deleting traveller information so the Customer can check that travellers are ready for a deployment. |
| Data subjects | The Customer's employees, contractors, freelancers and crew travelling for work, and the Customer's authorised users. |
| Personal data | Name, work email address, role and mobile number (optional); deployment destination and dates; passport issuing country and issue and expiry dates (no passport numbers or scans); entry-permission answers and visa or permit documents; requirement evidence such as site cards, qualifications and safety documents; device and connectivity details; arrival confirmation; activity records. |
| Special category data | Medical or fit-to-work certificates, only where the Customer chooses to request them. Kept for the shorter period in Annex 4. |
Annex 2: Security measures
- Data stored and processed in the UK (London) by the database, storage and hosting providers.
- HTTPS encryption for all connections; encryption at rest by the database provider.
- Company isolation enforced by database row-level security as well as application checks; per-deployment access for colleagues.
- Private evidence storage; documents open only through short-lived signed links (60 seconds) issued to authorised users.
- Personal traveller links that expire after 30 days; no traveller account needed.
- Email verification for new accounts; passwords of at least 12 characters with upper and lower case letters and a number.
- RoamGuard internal access limited to named operations staff with an admin role.
- An activity record of invitations, submissions, reviews and decisions, visible to the Customer.
- Card payments handled entirely by the payment provider; RoamGuard does not receive card numbers.
- Automatic deletion of evidence under Annex 4.
Annex 3: Sub-processors
| Sub-processor | Purpose | Location |
|---|---|---|
| Supabase Inc. | Database, file storage and authentication | London, UK |
| Vercel Inc. | Application hosting | London, UK (public website files cached globally) |
| Resend | Transactional email | United States |
| Stripe Payments UK Ltd | Card payments | UK, EU and United States |
| eSIM connectivity partners | Issuing eSIMs, only for travellers assigned a RoamGuard eSIM. Named on request | Varies by partner |
| Specialist partners | Immigration or work-authorisation advice, only for cases the Customer agrees to refer | Named for each case |
Annex 4: Retention schedule
| Data | Retention |
|---|---|
| Uploaded evidence (visas, permits, cards, certificates) | Deleted automatically 90 days after the deployment's last day |
| Health and safety documents, including medical certificates | Deleted automatically 30 days after the deployment's last day |
| Readiness record (statuses, dates checked, review decisions) | While the Customer account is active; deleted on request or when the Service ends |
| Invoices and payment records | RoamGuard's own records, kept as long as UK tax law requires (normally six years) |