Legal

Roamavo Privacy Policy

Last updated: June 20, 2026

This Privacy Policy explains how Roamavo LLC (“Roamavo,” “we,” “us,” or “our”) collects, uses, shares, stores, and protects personal information when you visit our website, create an account, purchase an eSIM data plan, use your Roamavo dashboard, contact support, or otherwise use our services.

Roamavo LLC is a United States limited liability company registered in Wyoming.

Business mailing address:Roamavo LLC30 N Gould St Ste RSheridan, WY 82801United States

Email: support@roamavo.comWebsite: roamavo.com

This Privacy Policy applies to our website, checkout, customer dashboard, emails, support channels, eSIM services, account features, and related services (together, the “Services”).

By using Roamavo, you agree to the collection and use of information as described in this Privacy Policy. This Privacy Policy should be read together with our Terms and Conditions, Refund Policy, Delivery Policy, and Cookie Policy.

1. Who We Are

Roamavo provides prepaid travel eSIM data plans for international travelers. Customers can choose a destination, purchase a data plan, receive digital eSIM installation details, and manage their eSIM through a Roamavo account.

Roamavo is not a mobile network operator. We work with third-party eSIM providers, telecommunications providers, roaming partners, network operators, payment processors, fraud-prevention providers, hosting providers, email providers, analytics providers, and customer support tools to provide the Services.

For purposes of applicable privacy laws, Roamavo LLC is generally the controller of the personal information we collect directly from customers through our website, account system, checkout, and support channels.

Some third-party providers, such as payment processors, mobile network operators, eSIM providers, analytics providers, and social login providers, may process your personal information under their own privacy policies or as independent controllers depending on the service.

2. Personal Information We Collect

We collect personal information in four main ways:

Information you provide directly.
Information collected automatically when you use our website or Services.
Information generated when you purchase, install, activate, or use an eSIM.
Information received from third-party providers such as payment processors, social login providers, fraud-prevention providers, and eSIM/network partners.

The types of personal information we collect may include the following.

3. Account and Identity Information

When you create an account, log in, verify your email, or manage your profile, we may collect:

Name, if provided.
Email address.
Password or authentication credentials.
Email verification status.
Login method, such as email/password, Google login, or Apple login.
Third-party login identifier if you use Google, Apple, or another supported login method.
Account creation date.
Account status.
User ID or internal account identifier.
Communication preferences.
Security and authentication logs.

We use this information to create and manage your account, verify your identity, secure your account, provide access to your dashboard, deliver your eSIM information, send service emails, and prevent unauthorized access.

4. Purchase, Billing, and Transaction Information

When you make a purchase, we may collect or receive:

Order number.
Plan purchased.
Destination or region.
Data amount.
Validity period.
Price.
Currency.
Quantity.
Discount code, coupon, credit, or promotional offer used.
Payment status.
Payment processor transaction ID.
Refund status.
Dispute or chargeback status.
Billing country, billing postal code, or billing address if required.
Tax information where required.
Invoice, receipt, or order history.
Fraud or payment-risk signals.
Last four digits of the card, card brand, or payment method type if made available by our payment processor.

We do not store full card numbers, full card security codes, or complete payment card details on our own systems. Payments are processed by third-party payment processors.

We use purchase and billing information to process orders, confirm payment, issue eSIMs, send receipts, calculate taxes where required, manage refunds, handle disputes, prevent fraud, comply with financial record-keeping obligations, and provide customer support.

5. Device, eSIM, and Installation Information

To provide and support eSIM services, we may collect or receive technical information related to your device and eSIM, including:

Device type.
Device model.
Operating system.
Browser type.
App or web version, where applicable.
Device language or region settings.
eSIM installation status.
eSIM activation status.
eSIM expiry status.
eSIM ICCID.
eSIM transaction number or provider reference.
eSIM profile status.
QR code or activation details generated for your order.
Manual installation details.
SM-DP+ address or activation code, where applicable.
Top-up eligibility.
Plan status, such as new, active, in use, depleted, expired, refunded, or cancelled.
Provider plan ID.
Operator or network information shown for your plan.
Device identifiers such as EID or IMEI only where required for provisioning, troubleshooting, fraud prevention, provider requirements, or support.

We use this information to provision your eSIM, display your eSIM in your dashboard, help you install and activate your plan, check top-up eligibility, troubleshoot problems, prevent misuse, and communicate with our eSIM provider or network partners.

6. Network, Usage, and Connectivity Information

When you use an eSIM or when our providers send us service status information, we may collect or receive network and usage information such as:

Data allowance.
Data used.
Data remaining.
Plan start date.
Plan expiry date.
Last usage update.
Activation date.
Connection status.
Supported network operator.
Country or region of use.
IP address used for network connection.
Session usage records.
Approximate connection time.
eSIM status events.
Top-up status.
Network identifiers required by eSIM providers or mobile network operators, which may include technical identifiers such as ICCID, IMSI, MSISDN-type identifiers, or similar telecommunications identifiers where applicable.

This data is used to deliver mobile data service, show remaining data in your dashboard, enforce plan limits, support top-ups, troubleshoot connection issues, detect abuse, comply with provider requirements, and respond to customer support requests.

Roamavo does not control the mobile networks used to provide connectivity. Local mobile network operators and roaming partners may process technical network data according to their own legal obligations and privacy practices.

7. Support and Communication Information

When you contact us or interact with support, we may collect:

Name.
Email address.
Order number.
Account information.
Destination and plan purchased.
Device model.
Screenshots you send.
Error messages.
Installation status.
Support ticket history.
Email content.
Chat messages.
Feedback.
Survey responses.
Troubleshooting information.
Refund request details.
Dispute or complaint information.

We use this information to respond to your requests, troubleshoot eSIM issues, review refund eligibility, improve customer support, prevent abuse, maintain records of our interactions, and improve the Services.

8. Website, Analytics, and Technical Information

When you visit our website or use our Services, we may automatically collect:

IP address.
Browser type and version.
Device type.
Operating system.
Pages viewed.
Referring page or campaign source.
Search terms entered on our website.
Country or approximate location based on IP address.
Date and time of visit.
Session duration.
Clicks, scrolls, and page interactions.
Checkout events.
Login events.
Error logs.
Performance logs.
Cookie identifiers.
Analytics identifiers.
Fraud-prevention signals.
Security logs.

We use this information to operate the website, understand how customers use the Services, improve design and performance, detect bugs, prevent fraud, secure accounts, measure marketing performance, and improve checkout conversion.

9. Cookies and Similar Technologies

We use cookies, pixels, local storage, SDKs, and similar technologies to operate and improve our website and Services.

Cookies may be used for:

Essential website functionality.
Login sessions.
Security.
Fraud prevention.
Shopping cart and checkout.
Remembering preferences.
Analytics.
Performance monitoring.
Marketing measurement.
Affiliate or referral tracking.
Customer support chat.
Advertising or retargeting, if enabled.

Some cookies are necessary for the website to function and cannot be turned off through our cookie tools. Non-essential cookies, such as analytics or marketing cookies where required by law, may be used only with your consent.

You can control cookies through your browser settings. If you block cookies, some parts of the website or checkout may not work properly.

We may publish a separate Cookie Policy with more details about the cookies and tools we use.

10. Information From Third Parties

We may receive information from third parties, including:

Payment processors.
Fraud-prevention tools.
Social login providers such as Google or Apple.
eSIM providers.
Network operators.
Roaming partners.
Analytics providers.
Email providers.
Support tools.
Affiliate or referral partners.
Marketing platforms.
Hosting and infrastructure providers.

For example:

If you log in using Google or Apple, we may receive your email address, name, profile identifier, and authentication confirmation.
If you complete a payment, our payment processor may send us payment status, transaction ID, payment method type, fraud signals, refund status, or dispute information.
If your eSIM is provisioned, our eSIM provider may send us ICCID, activation status, data usage, expiry date, top-up eligibility, or related plan information.
If you arrive through an affiliate or referral link, we may receive information needed to attribute the purchase.

We use third-party information only for the purposes described in this Privacy Policy.

11. How We Use Personal Information

We use personal information to:

Create and manage your account.
Verify your email address.
Authenticate logins.
Process payments.
Prevent payment fraud.
Create orders.
Provision eSIMs.
Deliver QR codes and installation details.
Display your eSIMs in your dashboard.
Show data usage and remaining data where available.
Support top-ups where available.
Send order confirmations and receipts.
Provide customer support.
Troubleshoot installation and connectivity issues.
Review refund requests.
Handle chargebacks and disputes.
Send important service and security messages.
Improve the website, dashboard, checkout, and support experience.
Monitor performance and fix bugs.
Detect fraud, abuse, account misuse, and security threats.
Enforce our Terms and Conditions.
Comply with legal, tax, accounting, and regulatory obligations.
Respond to lawful requests from authorities.
Manage promotions, coupons, credits, and referrals.
Send marketing messages where permitted.
Measure marketing and advertising performance.
Protect Roamavo, our customers, our providers, payment processors, and network partners.

12. Legal Bases for Processing

Depending on where you are located, privacy laws may require us to explain our legal basis for processing personal information.

We may rely on the following legal bases:

Contract Performance

We process personal information when necessary to provide the Services you request, including creating your account, processing your purchase, delivering your eSIM, displaying your plan, providing support, and managing refunds.

Legitimate Interests

We process personal information where necessary for our legitimate business interests, including fraud prevention, security, service improvement, analytics, troubleshooting, customer support, chargeback defense, internal administration, and enforcing our Terms, provided that those interests are not overridden by your privacy rights.

Consent

We rely on consent where required, such as for certain marketing emails, non-essential cookies, push notifications, or certain optional features.

You may withdraw consent at any time where processing is based on consent.

Legal Obligation

We process and retain personal information where necessary to comply with legal, tax, accounting, regulatory, law enforcement, sanctions, anti-fraud, and financial record-keeping obligations.

Vital or Public Interests

In rare cases, we may process or disclose information where necessary to protect safety, prevent harm, respond to emergencies, or comply with lawful public authority requests.

13. Marketing Communications

We may send you marketing emails about Roamavo offers, destinations, product updates, discounts, travel connectivity tips, or related services if permitted by law.

You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email or contacting us at support@roamavo.com.

Even if you unsubscribe from marketing emails, we may still send you transactional or service-related messages, including:

Login or verification emails.
Order confirmations.
Payment receipts.
eSIM delivery messages.
Security alerts.
Refund updates.
Policy updates.
Support messages.

14. How We Share Personal Information

We do not sell your personal information.

We share personal information only when necessary to provide the Services, operate our business, comply with law, protect rights, or with your consent.

We may share information with the following categories of recipients.

15. eSIM Providers, Network Operators, and Roaming Partners

We share necessary technical and order information with eSIM providers, telecommunications providers, mobile network operators, and roaming partners to provision and manage your eSIM.

This may include:

Provider plan ID.
Order reference.
ICCID.
eSIM transaction number.
Destination or coverage area.
Plan type.
Activation status.
Usage status.
Data usage and remaining data.
Network identifiers required to route service.
Troubleshooting information.
Top-up information.

These partners need technical information to deliver mobile data, activate eSIMs, route connectivity, manage network access, enforce usage limits, and troubleshoot issues.

16. Payment Processors

We share payment and order information with payment processors and related financial service providers to process payments, verify transactions, prevent fraud, issue refunds, and handle disputes.

Payment processors may collect payment card information directly from you. Roamavo does not store full card numbers or full card security codes on its own systems.

Payment processors may process your personal information according to their own privacy policies, security standards, and legal obligations.

17. Fraud Prevention and Security Providers

We may share information with fraud-prevention, identity verification, risk analysis, security, and abuse-prevention providers.

This may include:

IP address.
Device information.
Order details.
Email address.
Payment risk signals.
Account activity.
Transaction history.
Browser and session information.
Fraud or abuse indicators.

We use this information to protect customers, prevent unauthorized payments, reduce chargebacks, detect suspicious activity, secure accounts, and comply with payment processor requirements.

18. Service Providers

We use trusted service providers to operate Roamavo, including:

Website hosting providers.
Database providers.
Authentication providers.
Email delivery providers.
Customer support tools.
Analytics tools.
Error monitoring tools.
Cloud infrastructure providers.
Marketing tools.
Affiliate or referral tracking tools.
Accounting and finance tools.
Compliance tools.

These providers may access personal information only as necessary to provide services to Roamavo and are expected to protect that information.

19. Social Login Providers

If you use Google, Apple, or another social login method, we may share and receive information necessary to authenticate your account.

The social login provider may process your information under its own privacy policy. You should review the privacy policy of the provider you use.

20. Legal, Regulatory, and Safety Disclosures

We may disclose personal information to law enforcement, courts, regulators, government authorities, payment networks, banks, dispute-resolution providers, or other parties when we believe disclosure is necessary to:

Comply with law.
Respond to lawful requests.
Enforce our Terms and Conditions.
Protect our rights, customers, providers, or partners.
Prevent fraud, abuse, or security threats.
Investigate disputes or chargebacks.
Protect against legal liability.
Comply with tax, accounting, sanctions, or regulatory requirements.

Where legally permitted and practical, we may notify you of such requests, but we are not required to do so where prohibited by law or where notice would create risk.

21. Business Transfers

If Roamavo is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, change of control, or similar business transaction, personal information may be transferred as part of that transaction.

The receiving party will be expected to handle personal information in accordance with this Privacy Policy or provide notice of any material changes.

22. International Data Transfers

Roamavo serves customers globally. Your personal information may be collected, stored, processed, or transferred in countries other than where you live, including the United States and countries where our providers, processors, or infrastructure partners operate.

These countries may have privacy laws that are different from the laws in your country.

Where required by law, we use appropriate safeguards for international transfers, such as contractual protections, data processing agreements, Standard Contractual Clauses, or other legally recognized transfer mechanisms.

By using the Services, you understand that your information may be transferred to and processed in countries outside your country of residence.

23. Data Retention

We keep personal information only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our typical retention periods are:

Account Information

We keep account information while your account is active. After account closure, we may retain limited account records where necessary for legal, security, fraud-prevention, accounting, dispute, or business purposes.

Order and Transaction Records

We may keep order, invoice, payment, refund, and transaction records for up to 7 years, or longer if required by tax, accounting, legal, or financial regulations.

eSIM and Plan Records

We may keep eSIM, plan, activation, top-up, and service records for up to 3 years after the last activity on the plan, unless a longer period is needed for legal, provider, fraud-prevention, support, or dispute reasons.

Usage and Connectivity Records

We keep usage and connectivity data only as long as needed to provide the service, show remaining data, troubleshoot issues, support refunds or disputes, comply with provider rules, and prevent abuse. Some usage records may be kept for a shorter period, such as 30 days to 6 months, unless a longer period is required for legal, security, provider, or dispute reasons.

Support Records

We may keep support tickets, emails, chat messages, screenshots, and troubleshooting records for up to 3 years after the last interaction, unless longer retention is needed for legal claims, fraud prevention, disputes, or customer protection.

Marketing Records

We keep marketing consent and opt-out records for as long as needed to honor your preferences and prove compliance with applicable law.

Fraud, Abuse, and Security Records

We may retain fraud, abuse, chargeback, security, and risk records for as long as reasonably necessary to protect Roamavo, customers, providers, payment processors, and network partners, and to prevent repeated abuse.

When personal information is no longer needed, we will delete, anonymize, or securely dispose of it.

24. How We Protect Personal Information

We use reasonable technical, organizational, and administrative measures to protect personal information against unauthorized access, loss, misuse, disclosure, alteration, and destruction.

These measures may include:

HTTPS/TLS encryption in transit.
Encryption at rest where supported by our providers.
Access controls.
Authentication protections.
Limited access based on business need.
Logging and monitoring.
Secure cloud infrastructure.
Provider security reviews.
Data minimization.
Payment processing through PCI-compliant payment processors.
Fraud detection and abuse prevention.
Secure development practices.
Backups and disaster recovery procedures where appropriate.

No method of transmission or storage is completely secure. We cannot guarantee absolute security. You are responsible for keeping your account password and login credentials safe.

If you believe your Roamavo account or information has been compromised, contact us immediately at support@roamavo.com.

25. Your Privacy Rights

Depending on your location, you may have certain rights over your personal information.

These rights may include:

The right to access personal information we hold about you.
The right to correct inaccurate or incomplete information.
The right to delete personal information.
The right to restrict or object to certain processing.
The right to data portability.
The right to withdraw consent.
The right to opt out of marketing.
The right to opt out of certain sale, sharing, or targeted advertising uses where applicable.
The right to appeal a privacy decision where applicable.
The right to file a complaint with a data protection authority.

To exercise your rights, contact us at support@roamavo.com.

We may need to verify your identity before responding to a request. We may deny or limit a request where permitted by law, such as when we must keep information for legal, tax, security, fraud-prevention, payment dispute, provider, or business record purposes.

We aim to respond to privacy requests within 30 days, unless a longer period is allowed by applicable law.

26. European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area, United Kingdom, or Switzerland, you may have rights under applicable data protection laws, including the GDPR or UK GDPR.

You may have the right to:

Access your personal data.
Correct inaccurate personal data.
Request deletion.
Restrict processing.
Object to processing based on legitimate interests.
Request data portability.
Withdraw consent.
Object to direct marketing.
Lodge a complaint with your local data protection authority.

Roamavo LLC is generally the controller of personal information collected directly through our website, checkout, account system, and support channels.

We process personal information based on contract performance, legitimate interests, consent, legal obligations, and other lawful bases described in this Privacy Policy.

For international transfers from the EEA, UK, or Switzerland, we use appropriate safeguards where required.

To exercise your rights, contact support@roamavo.com.

27. United States Privacy Rights

If you are a resident of California or another U.S. state with applicable privacy laws, you may have additional rights regarding your personal information.

These rights may include:

The right to know what personal information we collect.
The right to access personal information.
The right to request deletion.
The right to correct inaccurate information.
The right to opt out of sale or sharing of personal information.
The right to opt out of targeted advertising, where applicable.
The right to limit the use of sensitive personal information, where applicable.
The right to non-discrimination for exercising privacy rights.
The right to appeal certain privacy decisions.

Roamavo does not sell personal information for money.

We do not knowingly sell or share personal information of children under 16.

We may use analytics, advertising, affiliate, or marketing tools that could be considered “sharing” or “targeted advertising” under some U.S. state privacy laws if enabled. Where required, we will provide a way to opt out of such use.

To exercise U.S. privacy rights, contact support@roamavo.com.

28. Categories of Personal Information Collected

For transparency, the categories of personal information we may collect include:

Identifiers, such as name, email address, account ID, IP address, device identifiers, transaction IDs, and eSIM identifiers.
Customer records, such as billing details, purchase history, receipts, refund records, and support records.
Commercial information, such as products purchased, destinations selected, plan details, order history, refunds, disputes, and account credits.
Internet or electronic network activity, such as website usage, pages viewed, clicks, session logs, device data, and error logs.
Geolocation-related information, such as approximate location based on IP address or destination/coverage area selected.
Device and technical information, such as device model, operating system, browser, eSIM status, and installation status.
Telecommunications-related technical identifiers, such as ICCID, IMSI, MSISDN-type identifiers, EID, IMEI, or similar identifiers where required for eSIM provisioning, support, or network access.
Payment-related information, such as payment method type, payment status, card brand, last four digits, processor transaction ID, billing country, and dispute status.
Communications, such as support emails, chat messages, feedback, and screenshots you provide.
Inferences, such as fraud-risk indicators, usage patterns, or service preferences.

Some of this information may be considered sensitive under certain privacy laws. We process sensitive information only as necessary to provide the Services, prevent fraud, secure accounts, comply with law, or where you have provided consent.

29. Sources of Personal Information

We collect personal information from:

You directly.
Your device and browser.
Your account activity.
Your purchases and checkout activity.
Payment processors.
eSIM providers.
Network operators and roaming partners.
Social login providers.
Fraud-prevention providers.
Analytics and advertising tools.
Customer support tools.
Affiliate or referral partners.
Hosting and infrastructure providers.

30. Purposes for Collecting Personal Information

We collect personal information for the purposes described in this Privacy Policy, including:

Providing eSIM data plans.
Processing payments.
Delivering installation details.
Managing accounts.
Showing dashboard data.
Providing customer support.
Troubleshooting technical issues.
Preventing fraud and abuse.
Improving the website and Services.
Marketing and promotions where permitted.
Handling refunds and disputes.
Complying with legal obligations.
Protecting Roamavo, customers, providers, and payment processors.

31. Do Not Sell or Share

Roamavo does not sell your personal information for money.

If we use advertising, analytics, affiliate, or tracking technologies that are considered “sharing,” “targeted advertising,” or “cross-context behavioral advertising” under applicable law, you may have the right to opt out.

You can contact support@roamavo.com to request an opt-out. Where we offer a cookie settings tool, you can also manage non-essential cookies there.

32. Global Privacy Control

Where required by applicable law and where our website tools support it, we may recognize Global Privacy Control or similar browser-based opt-out signals as a request to opt out of sale, sharing, or targeted advertising.

Because technology and legal requirements continue to develop, our handling of such signals may depend on the tools and jurisdictions applicable at the time.

33. Children’s Privacy

Roamavo is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

If you are under 18, you should use Roamavo only with permission from a parent or guardian.

If we learn that we have collected personal information from a child under 13 without appropriate consent, we will delete it as soon as reasonably possible.

If you believe a child has provided personal information to us, contact support@roamavo.com.

34. Third-Party Websites and Services

Our website or communications may contain links to third-party websites, apps, payment pages, social login providers, app stores, help pages, or partner services.

We are not responsible for the privacy practices, security, content, or policies of third-party websites or services.

When you use third-party services, their own privacy policies and terms may apply.

35. Payment Data Security

Payment card information is processed by third-party payment processors. Roamavo does not store full card numbers or full card security codes on its own systems.

Our payment processors may use payment information to:

Process payments.
Authenticate cards.
Prevent fraud.
Handle refunds.
Manage disputes.
Comply with payment network rules.
Meet legal and regulatory obligations.

You should review the privacy policy of the payment processor used at checkout.

36. eSIM Provider and Network Data

To provide eSIM services, certain technical information must be processed by eSIM providers, mobile network operators, and roaming partners.

These partners may process technical identifiers and network data needed to route connectivity, activate your eSIM, enforce plan limits, calculate usage, troubleshoot connectivity, support top-ups, and comply with telecommunications laws.

Roamavo receives only the information needed to provide customer service, manage your plan, show dashboard details, process refunds, detect misuse, and operate the Services.

37. Automated Decision-Making and Fraud Checks

We may use automated tools to help detect fraud, suspicious payments, account abuse, bot activity, unusual order patterns, promotion abuse, or security risks.

These tools may flag, delay, cancel, or require review of an order.

Where required by applicable law, you may have the right to request human review of certain automated decisions. Contact support@roamavo.com if you believe an automated decision affected your order or account.

38. Account Deletion

You may delete your Roamavo account directly from the Profile section of your account dashboard. You may also request account deletion by contacting us at support@roamavo.com.

Deleting your account may remove access to your dashboard, order history, eSIM details, and support history.

We may retain certain information after account deletion where necessary to:

Complete active orders.
Provide refunds.
Prevent fraud.
Comply with tax and accounting obligations.
Resolve disputes.
Defend legal claims.
Comply with provider or payment processor obligations.
Maintain security records.
Enforce our Terms.

Where we cannot delete information immediately, we will limit retention to what is necessary and delete or anonymize it when no longer required.

39. Data Accuracy

You are responsible for providing accurate account, billing, and contact information.

If your email address is incorrect, you may not receive order confirmations, login codes, support messages, refund updates, or eSIM delivery information.

You can update certain account information through your dashboard or by contacting support@roamavo.com.

40. Data Breach Notification

If we become aware of a security incident involving personal information, we will investigate and take appropriate steps.

Where required by law, we will notify affected users and/or regulators.

Notification may be made by email, account notice, website notice, or another method permitted by law.

41. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, technology, providers, legal requirements, or business practices.

When we update the Privacy Policy, we will change the “Last updated” date at the top.

If changes are material, we may provide additional notice, such as by email, website notice, or account notice.

Your continued use of Roamavo after an updated Privacy Policy becomes effective means you accept the updated Privacy Policy.

42. Contact Us

If you have questions about this Privacy Policy, want to exercise your privacy rights, or have a concern about how we handle personal information, contact us:

Roamavo LLC30 N Gould St Ste RSheridan, WY 82801United States

Email: support@roamavo.comWebsite: roamavo.com

We aim to respond to privacy requests within 30 days.