1. Introduction

Romarex operates a digital membership access platform. Transactions are processed independently by Merchant-of-Record providers: Nexway for digital memberships and ExpandNow for physical product transactions.

This policy clarifies Romarex’s role in data processing and the separation from Merchant-of-Record providers.

2. Roles & Data Controller Structure

2.1 Platform Operator Role

Romarex operates solely as a technology platform and does not act as Merchant-of-Record. Data is processed for account management, membership access, platform usage analytics, and customer support.

Romarex does not collect full payment card details or process financial transactions.

2.2 Merchant-of-Record Controllers

Nexway acts as the independent data controller for membership payments, while ExpandNow acts as the controller for physical product transactions. Each maintains separate privacy policies governing payment data.

3. Information We Collect

3.1 Information You Provide

• Full name
• Email address
• Account login credentials
• Contact information
• Shipping details if initiating product orders

3.2 Automatically Collected Information

• IP address
• Device and browser data
• Cookies and tracking technologies
• Usage patterns and interaction data

3.3 Transaction Metadata

Limited membership or order status confirmations may be received from Merchant-of-Record providers without payment card details.

4. How We Use Personal Information

• Provide and manage membership access
• Authenticate and secure accounts
• Improve platform functionality
• Prevent fraud or unauthorized activity
• Respond to customer inquiries
• Comply with legal obligations

5. Legal Bases for Processing

• Contractual necessity for membership services
• Legitimate interests such as security and improvements
• Legal compliance obligations
• Consent where required (e.g., cookies or marketing)

6. Sharing Personal Information

Merchant-of-Record Providers

Data required for transactions may be shared with Nexway (memberships) or ExpandNow (physical goods).

Service Providers

• Hosting infrastructure
• Email delivery services
• Analytics and monitoring tools

Legal Disclosure

Information may be disclosed if required by law, regulation, court order, or fraud investigations.

7. International Data Transfers

Data may be processed in the United States or other jurisdictions where service providers operate. Appropriate safeguards such as contractual protections may be used where required.

8. Data Retention

Personal data is retained only as necessary for membership administration, legal compliance, fraud prevention, and accounting records. Transaction records follow Merchant-of-Record retention requirements.

9. Cookies & Tracking Technologies

Cookies help maintain sessions, analyze usage trends, and improve user experience. Browser settings may control cookies, though some features may not function properly if disabled.

10. Your Privacy Rights

• Access personal data
• Correct inaccuracies
• Request deletion
• Restrict or object to processing
• Request data portability

Contact contact@romarex.com for platform data requests. Payment-related inquiries should be directed to the relevant Merchant-of-Record.

11. California Privacy Rights

California residents may request disclosure of collected data, deletion of personal data, and information about data sharing. Personal information is not sold.

12. Data Security

Reasonable technical and organizational safeguards are implemented, but absolute security cannot be guaranteed.

13. Minors

The platform is intended for users 18 years or older. Personal data from minors is not knowingly collected.

14. Updates to Privacy Policy

This policy may be updated periodically. Continued use of the platform after updates constitutes acceptance of the revised policy.

15. Contact Information

Romarex Global LLC
📧 contact@romarex.com
📍 30 N Gould St, STE R, Sheridan, WY 82801, USA