TapRoam — Website Terms & Conditions (including Privacy Policy) Last updated: 6 October 2025 1) Who we are 1.1 TapRoam is a trading name of 853 Holdings Limited (“853 Holdings”, “we”, “us”, “our”), a company registered in England & Wales (Company No. 16719288). 1.2 Registered with the UK Information Commissioner’s Office (ICO) — Registration Reference ZC007038. 1.3 VAT Registered (Number pending). 1.4 TapRoam is powered by Ooliant, a platform for managing information, users and workflows, owned and operated by 853 Holdings Limited. 1.5 Contact (general): admin@ooliant.com . 1.6 Registered office (insert when ready): (insert registered office address). 2) Acceptance of these Terms 2.1 By accessing our website, creating an account and/or purchasing any product or service (together, the “Service”), you agree to be bound by these Terms & Conditions (“Terms”). 2.2 If you do not agree to these Terms, you must not use our website or Services. 2.3 We may update these Terms from time to time by posting a new version here. Your continued use constitutes acceptance of changes. 3) Eligibility & acceptable use 3.1 You confirm you are at least the age of majority in your jurisdiction (or you have parental/guardian consent for any minor dependants using the site). 3.2 You must not use the Service for any unlawful or unauthorised purpose, or in a way that infringes the rights of others. 3.3 Prohibited uses include (without limitation): illegal activity; infringement of IP; harassment or discrimination; submitting false or misleading information; introducing malware; scraping without permission; attempting to circumvent security; or any activity that disrupts or degrades our systems or those of our partners. 4) Accounts, accuracy & security 4.1 You agree to provide current, complete and accurate information, and to keep it updated (including email, billing details and device phone model where relevant to eSIM activation). 4.2 You are responsible for safeguarding your login credentials and for all activities under your account. Notify us immediately of any suspected unauthorised use. 5) Products & Services (including eSIMs) 5.1 Product descriptions, availability and pricing may change without notice. Reasonable efforts are made to display images and colours accurately; your device display may vary. 5.2 We may limit sales to any person, region or jurisdiction and may discontinue any product or plan at any time. 5.3 Technical requirements. eSIMs require compatible, network-unlocked devices and correct setup. You must follow our setup instructions at checkout/in your account/help pages (including, where applicable, disabling Automatic Data Switching, selecting the eSIM for data, and enabling data roaming if required). 5.4 Third-party networks. Network coverage, speeds and performance are provided by third-party carriers. Availability may vary by location and device. 6) Orders, pricing & payment 6.1 Placement of an order is an offer; acceptance occurs only when we issue a confirmation and/or make the eSIM/profile available. We may refuse or cancel an order (e.g., suspected fraud, mispricing, regulatory reasons). 6.2 Prices are shown in the currency indicated at checkout and may include taxes where applicable. If VAT applies, a VAT invoice will be issued once our VAT number is active. 6.3 Payments are processed securely via PCI-DSS compliant third-party gateways (e.g., Square, PayPal, Stripe). We do not store full card details on our servers. 7) Activation, reimbursements & refunds (eSIM-specific) 7.1 To ensure correct functionality you must follow our setup instructions. TapRoam/853 Holdings is not responsible for performance issues caused by incorrect setup, device locks, unsupported devices, or user-modified settings contrary to our guidance. 7.2 Refund eligibility. a) If an eSIM cannot be activated due to a technical issue originating from the network (carrier fault) and you have followed our instructions and cooperated with troubleshooting, you may request a refund or exchange. b) Activated eSIMs and partially used data are generally non-refundable unless required by law or the issue is verified as network-originating. c) All refund requests require proof of purchase and demonstrable steps taken per our setup guide. 7.3 Where a plan includes time/data allowances starting from activation/first use, we are not responsible for allowances consumed by device background activity or roaming settings on your device. 7.4 Any goodwill credits or refunds are at our sole discretion, without prejudice to your statutory rights. 8) Delivery of digital items 8.1 eSIMs/profiles, QR codes and/or installation links are delivered digitally to your account or email. You are responsible for ensuring you can access your email/account and scan/install promptly. 9) Modifications to the Service 9.1 We may modify, suspend or discontinue any part of the Service (including plans or features) at any time. We will endeavour to avoid material adverse changes to already-purchased plans, but some changes may be outside our control (e.g., carrier decisions, regulatory requirements). 10) Optional tools & third-party links 10.1 We may provide access to third-party tools “as is” and “as available” without warranties. Your use is at your own risk and subject to those third-parties’ terms. 10.2 Our site may contain links to third-party websites. We are not responsible for their content or privacy practices. 11) User content, feedback & reviews 11.1 If you submit ideas, reviews, comments or other materials (“Comments”), you grant us a worldwide, non-exclusive, royalty-free licence to use, reproduce, adapt, publish and display such Comments for Service operation, marketing and improvement. 11.2 We may monitor, edit or remove content we consider unlawful, infringing or otherwise objectionable. 12) Intellectual property 12.1 The TapRoam website, content, the Ooliant platform and related IP are owned by 853 Holdings or its licensors. All rights reserved. 12.2 You must not copy, reproduce, sell, resell or exploit any part of the Service without our prior written consent. 13) Errors & availability 13.1 Occasionally there may be information containing typographical errors, inaccuracies or omissions (e.g., pricing, plan descriptions). We may correct these and cancel orders if necessary, including after submission. 14) Warranty disclaimer 14.1 Except where required by law, the Service is provided on an “as is” and “as available” basis without warranties of any kind, express or implied (including merchantability, fitness for a particular purpose, non-infringement). Network performance is the responsibility of the carrier. 15) Limitation of liability 15.1 To the maximum extent permitted by law, 853 Holdings (including directors, officers, employees and agents) is not liable for: loss of profits, revenue, savings, data, business opportunity, or any indirect, incidental, special or consequential loss arising from or in connection with the Service or these Terms. 15.2 Our total aggregate liability for all claims relating to the Service in any 12-month period shall not exceed the amount you paid to us for the affected Service in that period. 15.3 Nothing in these Terms limits liability for death or personal injury caused by negligence, fraud, or any liability that cannot be limited under law. 16) Indemnity 16.1 You agree to indemnify and hold harmless 853 Holdings and its affiliates from any third-party claims arising out of your breach of these Terms, infringement of third-party rights, or unlawful use of the Service. 17) Suspension & termination 17.1 We may suspend or terminate access immediately if you breach these Terms, if we suspect fraud/abuse, or if required by law or our suppliers/carriers. 17.2 On termination you remain liable for amounts due up to the date of termination. Clauses intended to survive termination shall do so. 18) Promotions & competitions (if offered) 18.1 Competitions/Promotions. From time to time we may run promotions. Each will have specific rules (eligibility, timing, selection, prize, publicity, exclusions). Where not inconsistent with those rules, the general principles below apply: Open to UK residents 18+ (unless stated otherwise). No purchase necessary (unless stated). One entry per person unless otherwise stated; automated/bulk entries excluded. Winners selected fairly (e.g., random draw) and notified via the official TapRoam channel. No cash alternative; prizes non-transferable; subject to availability. We may verify identity/eligibility and may disqualify entries for breach of rules or abuse. Publicity: winners may be asked to participate in reasonable publicity with no additional compensation. Promotions are not sponsored or administered by unaffiliated social platforms. 19) Privacy Policy (UK/EU GDPR compliant) Controller: 853 Holdings Limited (trading as TapRoam). Contact (privacy): admin@ooliant.com . 19.1 What Data We Collect a) Personal Identification Data — full name; email; phone (optional); billing information; IP address. b) Order & Payment Data — order details (products purchased, date, price); payment method (processed via third-party gateways such as Square, PayPal, Stripe). c) Technical Data — device type, OS, browser; log data (pages visited, timestamps, referral sources). d) Business Reseller Data (if applicable) — brand name; company email; encrypted reseller-portal credentials. 19.2 How We Collect Your Data Forms on our website (checkout, contact, reseller signup) Emails or direct contact Cookies and tracking technologies Analytics tools (e.g., Google Analytics, Meta Pixel) 19.3 Why We Process Your Data (Purposes) To process orders and deliver eSIM services To manage your account and provide support To verify identity and ensure account security To process reseller applications and transactions To notify you of service updates, offers or promotions (with consent where required) To improve our site and services via usage analytics To comply with legal obligations and resolve disputes 19.4 Legal Bases (UK/EU GDPR) Consent (e.g., marketing emails) Contract (e.g., processing your eSIM order) Legitimate interests (e.g., improve services, prevent fraud) Legal obligation (e.g., accounting/tax records) 19.5 Storage & Security Data stored securely with encryption, firewalling and role-based access control. Payment data handled only by PCI-DSS compliant processors; we do not store full card PANs. Retention only as long as necessary for the purposes above or to meet legal obligations. 19.6 Sharing & Disclosure We do not sell or rent your personal data. We may share with: Trusted providers (hosting, analytics, email, payments, anti-fraud, customer support) Law enforcement/regulators where legally required Affiliates/partners for fulfilment or service enhancement under confidentiality 19.7 International Transfers Where data is transferred outside the UK/EEA, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) or the UK IDTA (or other adequacy mechanisms). 19.8 Your Rights You may: access, rectify, erase, restrict or object to processing; portability; withdraw consent (for consent-based processing); and complain to the ICO. ICO: ico.org.uk or 0303 123 1113. To exercise rights, contact admin@ooliant.com . 19.9 Cookies & Tracking We use cookies to: improve performance/security; remember preferences; analyse behaviour (Google Analytics, Meta Pixel); and support marketing/remarketing. You can manage cookies in your browser. See our separate Cookie Policy for details (link to be added). 19.10 Children’s Privacy Our Services are not intended for individuals under 16. We do not knowingly collect data from minors; if discovered, we will delete it. 19.11 Third-Party Links We are not responsible for third-party privacy practices. Review their policies before providing data. 19.12 Data Breach Where legally required, we will notify affected users and relevant authorities within 72 hours of becoming aware of a qualifying personal data breach. 19.13 Changes to this Privacy Policy We may update this policy periodically. The latest version will be posted here; material changes may be notified by email where appropriate. 20) Complaints & customer service 20.1 If you have a concern, contact admin@ooliant.com . We aim to resolve issues promptly and fairly. 20.2 You also have the right to escalate privacy complaints to the ICO (see 19.8). 21) Governing law & jurisdiction 21.1 These Terms (and any non-contractual obligations arising out of or in connection with them) are governed by the laws of England and Wales. 21.2 The courts of England and Wales have exclusive jurisdiction, except that consumers resident elsewhere in the UK/EU may benefit from mandatory consumer protections and bring claims in their local courts where applicable. 22) Miscellaneous 22.1 Entire agreement. These Terms and the policies referenced (Privacy Policy, Cookie Policy, any Promotion Rules) constitute the entire agreement between you and us. 22.2 Severability. If any provision is held unlawful, void or unenforceable, the remainder remains in effect. 22.3 No waiver. Failure to enforce a provision is not a waiver. 22.4 Assignment. We may assign/transfer our rights and obligations; you may not assign without our prior written consent. 22.5 Notices. We may contact you via the email associated with your account or by posting on the website.