Privacy Policy

1. Information We Collect

We collect information that you provide directly to us and information that is automatically collected when you use our services.

2. How We Use Your Information

We use the collected information for the following purposes:

• Provide, maintain, and improve our eSIM services
• Process transactions and send service notifications
• Authenticate users and prevent fraud
• Comply with legal obligations and regulatory requirements
• Analyze usage patterns to enhance user experience
• Send marketing communications (with your consent)
• Provide customer support and respond to inquiries
• Detect and prevent technical issues or security threats

3. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract Performance: To provide our services and fulfill our contractual obligations
• Legitimate Interest: To improve our services, prevent fraud, and ensure security
• Legal Obligation: To comply with applicable laws and regulations
• Consent: For marketing communications and optional features (you may withdraw consent at any time)

4. How We Share Your Information

We do not sell your personal information. We may share your data with:

• Mobile Network Operators: To provide eSIM connectivity and network services
• Payment Processors: To process transactions securely
• Service Providers: Third parties who assist in operating our services (hosting, analytics, customer support)
• Legal Authorities: When required by law or to protect our rights and safety
• Business Transfers: In connection with a merger, acquisition, or sale of assets

All third-party service providers are contractually obligated to protect your information and use it only for specified purposes.

5. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specifically:

• Account information is retained while your account is active
• Transaction records are kept for 7 years for tax and accounting purposes
• Usage logs are retained for 12 months for network optimization
• Marketing preferences are stored until you withdraw consent

You may request deletion of your data at any time, subject to legal retention requirements.

6. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by regulatory authorities
• Adequacy decisions recognizing equivalent protection
• Your explicit consent for specific transfers

7. Your Privacy Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your personal information
• Correction: Update or correct inaccurate data
• Deletion: Request deletion of your personal information
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to certain processing activities
• Restriction: Request limitation of processing in certain circumstances
• Withdraw Consent: Withdraw consent for processing based on consent

To exercise these rights, please contact us using the information provided at the end of this policy. We will respond within the timeframe required by applicable law.

8. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Employee training on data protection practices
• Incident response procedures for data breaches

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

9. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information promptly.

10. Third-Party Links and Services

Our services may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

11. Marketing Communications

With your consent, we may send you promotional emails, SMS messages, or push notifications about our products, services, and special offers. You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in our emails
• Replying STOP to SMS messages
• Adjusting notification settings in the app
• Contacting our customer support

Please note that even if you opt out of marketing communications, we will still send you service-related notifications necessary for your account.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect, use, and disclose
• Right to request deletion of personal information
• Right to opt out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

To exercise these rights, please submit a verifiable request through our contact methods below.

13. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR), including those outlined in Section 7. You also have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on our website
• Sending an email notification to your registered address
• Displaying a prominent notice in our app or services

Your continued use of our services after such notification constitutes acceptance of the updated policy.

15. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee our privacy and data protection practices. If you have questions or concerns about how we handle your personal information, you may contact our DPO directly.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: