Personal Information We Collect
By creating an account, utilizing our services, downloading or utilizing any of our mobile applications, or engaging in a purchase, you are willfully disclosing certain information to us that we gather, which may include but is not limited to your name, email address, physical address, mobile number, and additional details. Please refer to Section 2 of this document for further details.
To gauge usage and offer you information that we consider to be relevant, we may employ tracking technologies such as cookies. Additional information can be found here.
In the event that you access our Site using a mobile device, we may obtain further information from you, such as the mobile carrier, operating system, and unique device identifier.
You can also give us information when engaging with our content via third-party social media sites, plug-ins, or applications.
Uses, Retention and Storage
Through your use of our Site, you are consenting to the sharing of Information we collect, to the extent permitted by applicable law, with our subsidiaries and affiliates, as well as with our service providers, third parties, and other entities, including job posting third-party websites, potential employers or individuals searching for candidates, legal authorities, and others (in the event of a change of control), as well as social networks and companies in the mobile app industry.
You have the ability to manage the manner and timing of receiving information from us, as well as the categories of data we may share. Additionally, you may object to the processing of your information, request deletion of the information we have collected from you, and obtain a copy of the aforementioned information. Click here for other information choices.
Access and Review Options
At any time, you have the option to modify your information by editing your profile, altering or deleting posted content, or closing your account.
European Economic Area Residents: Special Notice Concerning the General Data Protection Regulation ("GDPR")
The Provider adheres to GDPR guidelines, thereby granting applicable data subjects their privacy rights.
California Residents: Special Notice Concerning the California Consumer Protection Act (“CCPA”)
The Provider complies with CCPA regulations, thereby providing California residents their relevant privacy rights to the extent they are applicable.
If you have any inquiries regarding this Policy, you may send them to email@example.com or to any other contact information provided in this Policy.
Last Updated: April 19, 2023
1. Scope and Consent
2. Information We Collect About You
Information we collect about you depends on how you use our Site.
(a) Registration, Services and Account information. If you choose to browse our Site without registering for an account, we may still collect certain information, such as data related to your device, geolocation, behavior, target job, User Content, and target profile. However, in order to create an account and access certain services (such as Site email accounts, SIM Search, etc.), as well as to make purchases or interact with our Site, you will be required to provide us with certain information, including a valid email address and username. Failure to provide this information will prevent you from creating an account. Additionally, to make purchases, you will be required to provide payment information, such as credit or debit card details, billing address, and name. Please note that we do not store credit card information and rely on a service provider to process transactions. This information will only be associated with your account after you have successfully registered. We may also collect other voluntarily provided data, such as name, surname, contact details, and any User Content you create on the Site.
(b) Information to Respond to Your Requests. You have the option to provide us with your contact information, such as your email address, to enable us to address your requests. Information on how to opt-out of receiving communications from us can be found in the section titled "Accessing, Reviewing, and Changing Your Personal Information."
(c) Third party log-in. When you log in to the Site using third-party credentials, we may gather some essential details like your name, username, and email address.
(e) Information from other sources. We may combine the information we collect with publicly available information to the extent permitted by the laws of your country of residence.
(f) Mobile Information. By agreeing to this Policy you consent that we may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location, mobile number, your text messages, emails or email address, and user name).
(g) Privacy Notice and Information We Collect. We gather information from the location storage linked with your web browser, including your browsing activity for SIM search queries, automatically. Additionally, we access local storage associated with your web browser to record your interactions with specific webpages. We collect this information for statistical purposes, to analyze how our website and browser extensions are used, and to improve your experience. We also use this information to facilitate your SIM purchases on our website or third-party websites, and to deliver advertising or other content that we think may interest you based on your browsing behavior on the internet.
3. Limited User Policy
a). (App’s) use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.”
b). Our app may use information received from Google APIs to personalize the user experience, such as displaying personalized content or recommendations. However, we will use the data only for this purpose and will not share it with any third-party app or service.
c). Our app may use information received from Google APIs for analytics purposes, such as measuring app usage or performance. However, we will use the data only for this purpose and will not share it with any third-party app or service.
d). Our app does not use information received from Google APIs for advertising purposes, such as displaying targeted ads. We believe in respecting user privacy and will not share user data with any third-party app or service for advertising purposes.
e). Our app may use information received from Google APIs for research purposes, such as studying user behavior or preferences. However, we will use the data only for this purpose and will not share it with any third-party app or service.
f). Our app may use information received from Google APIs to provide support and assistance to users. However, we will use the data only for this purpose and will not share it with any third-party app or service.
g).Holiday eSIM uses information received from Google APIs according to Google API Services User Data Policy, including Limited Use requirements. You can read more about the guidelines we adhere to when requesting your data from Google here. (https://developers.google.com/terms/api-services-user-data-policy)
4. Uses, Retention and Storage
We process your information for the following purposes and legal bases:
(a) Operate our Site and Provide You with Our Services. Specifically, we use the information to (1) respond to your questions and requests; (2) provide customer service such as fulfilling product and service orders, resolving disputes, administering contests or promotions, and providing information to third parties at your request; (3) personalize your experience by providing targeted advertising and content that we believe will be of interest to you; (4) improve the Site; (5) provide you with a safe, efficient, and customized experience; and (6) share it with third parties to deliver product enhancing tools and a wider set of services to help in your buying experience.
(b) Analyze and Aggregate Non-Personal Information. We use the Information we collect to analyze Site and user behavior and prepare aggregated reports. This includes aggregate information about our users and non-personal information.
(d) Marketing & Communications. We use the information we collect to contact you for marketing and communication purposes, such as maintaining the Site and your account, complying with your communication preferences, providing services as described at the time of collection, and contacting you for other purposes authorized by law.
We retain Information for as long as needed to achieve the purposes for which it was collected, for our business purposes, and/or to comply with applicable laws and regulations, to the extent permitted by such laws.
The information we collect may be shared with the following:
(a) The Provider Corporate Family: We may share your information with our affiliates and subsidiaries, and if we do so, their use and disclosure of your information will be subject to this Policy.
(b) Service Providers: We may share your information with service providers under contract who assist us in our business operations, such as fraud investigations, bill collection, payment processing, site analytics, and operations as described in Section 8 below. For a full list of processors and sub-processors, please contact us at firstname.lastname@example.org.
(c) Additional Services Requests: If you express interest in or register for other services on the Site, we will provide your information to those third parties or parties working on their behalf to fulfill your request. We may also share your information with third parties, such as e-SIM providers, third-party websites, third parties in the SIM selling industry, or other third parties interested in receiving the information we collect about you on the Site. You can opt-out of this sharing at any time by modifying your settings on your Account or contacting our Customer Service team.
(d) Legal and Law Enforcement: We may disclose information we collect if we believe it is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or subpoena.
(f) Ad Networks: We work with third parties on the Site to serve advertisements, provide us with data collection, reporting, ad response measurement, site analytics, and delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own tracking technologies/cookies.
(g) Analytics Providers: We may share information we collect through our Site with analytics providers, such as Google Analytics, to evaluate usage of our Site, improve our services, performance, and user experiences.
(i) Aggregate and De-Identified Information: We may share aggregated and de-identified information with third parties for marketing, advertising, research, or similar purposes.
6. Accessing, Reviewing, and Changing Your Personal Information
Users who have registered on the Site have the ability to review and modify their Information by accessing their accounts via the My Account and My Settings tabs. If there are any changes or inaccuracies in the Information, it is the responsibility of the user to update it promptly.
7. Your Choices
Attention EU users: Please refer to Section 10 below for information about your rights under the GDPR.
(a) Opting out of Promotional Messages: If you do not want to receive our promotional messages, you can click on the "My Account" tab, then select "My Settings" and "Preferences". You may also unsubscribe by clicking the link in the footer of any email or newsletter you receive. Alternatively, you can send us an email at email@example.com.
(b) Updating, deleting or changing your products: To make changes to or delete products you have purchased on our site, log in to your account, click on the "Products" tab, and select "Edit" or "Delete".
(c) Site Privacy Settings: Please be aware that any information you disclose on the Site while participating may be publicly visible and subject to redistribution by us and any third party that reviews your profile or information. You can change your privacy preferences at any time by logging in to your account and clicking on "My Settings". You can also set your preferences for other Provider services as outlined in Section 5 or by contacting us as outlined in Section 17. Please note that Provider is not responsible for any uses, disclosures, or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.
(d) Administrative/Transactional Messages cannot be turned off: As we provide an online service, you cannot opt-out of administrative or transactional emails (such as emails about your transactions or policy changes) for your registered account.
(g) Other Data Options. Unless the laws of the country you reside in require otherwise, you have the right to request: (i) a copy of the personal identifiable information we have collected about you within the last 12 months from the date of your request; and (ii) disclosure of certain information about how we have handled your personal identifiable information in the prior 12 months. You can make such requests by logging into your account if you have created one, by utilizing the options available on our site, or by sending an email to firstname.lastname@example.org if you have not created an account.
(i) Timing and Third Parties. We will attempt to fulfill your requests as soon as reasonably possible, but please note that changes you request may not always be immediately effective. Furthermore, in certain situations, and subject to applicable law, Provider may be unable or unwilling to comply with some or all of your individual requests. We reserve the right to refuse and/or charge a monetary fee for requests that are manifestly unfounded or excessive. Unless required by law, we are not responsible for informing third parties with whom we have already shared your information of any changes you request pursuant to this section, nor are we responsible for removing information from or causing information to be removed from the databases or records of such third parties.
8. Information You Share on the Site
(a) Public Information: When you use Provider services, such as e-SIM purchase or creating a profile, you may post your information on Provider's searchable database or third-party sites. If you post information or content, such as your desired travel locations or e-SIM requirements, the posted information will be publicly available and searchable. Provider may aggregate and share this information with third parties to perform our services. Your privacy preferences can be set to determine how public or private you prefer your account. Please refer to third-party sites' privacy policies to learn more about their privacy practices.
(b) Other Services: If you use the Site, a universal application derived from the information you provide will be created and visible to potential employers and others with immediate needs. Therefore, your Site Profile and/or Digital Profile will be publicly viewable. You can restrict your Profile by editing your settings preferences on your Dashboard. Employers or third parties may use the contact information you have provided to contact you, but this consent is not a condition to having access to the Site or Provider services.
(c) Scores, Ratings, and Other Tools: The Site may provide tools that offer matching, checking, and recommendation mechanisms regarding the information you have provided in the system when searching for e-SIM products. These tools are computer-based algorithms designed to help you in your search, but they do not guarantee that you will receive a confirmed SIM. When using these tools, you understand that Provider cannot ensure that you will be contacted by an employer or receive a SIM offering.
9. Tracking Technologies (Cookies)
Upon your initial access to this Site, depending on your country of residence, you may have been prompted to establish your cookie settings. These settings will be saved for 12 months, in accordance with privacy laws. If you did not set your cookie preferences, when you visit our Site, we collect usage information from your computer, mobile, or other access device that informs us of your actions on the Site, such as video viewing, site views, key stroke data, mouse movement, scrolling, clicks, and typing ("usage information"). We utilize tracking technologies, including cookies, unique device identifiers, web beacons/GIFs, embedded scripts, e-tags/cache browsers, and cross-device tracking to gather usage information for various purposes, including:
(a) Operationally-Necessary: We use tracking technologies necessary for system administration to prevent fraudulent activity, improve security, or enable shopping cart functionality. We are not obligated to inform you or obtain your consent for tracking technologies that are operationally necessary.
(c) Functionality-Related: We may use tracking technologies to ascertain if you have previously visited the Site or are a new visitor, and to assist us in identifying which features you are most interested in.
(d) Targeting-Related: We may use tracking technologies to provide content, including ads, tailored to your interests on our online service and third-party websites, based on your interaction with our ads or content, as well as to track the content you access, including video viewing. Further information on this, along with opt-out choices, is provided in the “Your Choices” section above.
When you log in, we may collect your password information, as well as computer and/or connection information. During some visits, we may use software tools to capture and measure session information, such as page response times, download errors, time spent on specific pages, and page interaction data.
Tracking technologies, such as cookies, are generally alphanumeric identifiers that we transfer to your computer's hard drive via your web browser for record-keeping purposes. When you visit the Site, we and our business partners may utilize tracking technologies to enhance your online experience or personalize our offerings. Some cookies enable easier navigation of our Site, while others facilitate a faster login process. Some customers may have a privacy settings option available to establish their cookie preferences.
A few additional important things you should know about our use of tracking technologies (cookies):
Certain features of our site are only available through the use of tracking technologies.
We use both session cookies (which are temporary and last until you close your browser) and persistent cookies (which stay on your computer until you delete them).
You can decline the use of tracking technologies if your browser allows it, although doing so may affect your use of our site. Refer to your browser's help section, extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
We protect and encrypt the tracking technologies that we use, so that only we can read the information stored in them. However, you may encounter tracking technologies from our third-party service providers, such as Google Analytics, which help us with various aspects of our site's operations and services.
You may also come across tracking technologies from third parties on pages of our site that we do not control or authorize, such as if you view a web page created by another user.
Clear GIFs, which are tiny graphics with a unique identifier, are similar to cookies but are embedded invisibly on web pages. We use clear GIFs (also called web beacons, web bugs, or pixel tags) on our site to track visitor activity, manage content, and gather statistics on site usage. We and our third-party service providers may also use clear GIFs in HTML emails to track email response rates, identify when emails are viewed, and track forwarding.
10. Notice to Residents of the European Economic Area
The Provider adheres to the General Data Protection Regulation (GDPR) and ensures that all European data subjects are afforded their respective data privacy rights, as applicable. These rights include:
(i) Right to rectify inaccurate data: You have the right to request the correction of any inaccurate personal information we hold about you. In addition, if your personal information is incomplete, you have the right to request that it be completed.
(ii) Right to erasure (deletion of your personal information): You have the right to request the deletion of your personal information if it is no longer necessary for the purposes for which it was collected or processed, or if you withdraw your consent and there is no other legal basis for processing your data. You also have the right to request deletion if your data has been unlawfully processed, or if it must be erased to comply with a legal obligation.
(iii) Right to restrict processing of your personal information: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data, when the processing is unlawful, or when we no longer need the data but you require it for legal claims.
(iv) Right of data portability: If we collected your personal data through automated means and the legal basis for processing was either your consent or a contract, you have the right to receive that data in a machine-readable format. You may also request that we transfer your data to another controller, where technically feasible.
(v) Right to withdraw consent: You may withdraw your consent to the processing of your personal information at any time, without affecting the lawfulness of processing based on consent before its withdrawal. This includes your right to withdraw consent to the sharing of your data for monetary compensation with a third party.
(vi) Right to object: You have the right to object to the processing of your personal information, except in cases where we can demonstrate compelling, legitimate grounds for the processing that override your interests, rights, and freedoms. You may also object to the processing of your data for direct marketing purposes.
(vii) Right to access and to obtain a copy of personal data: You have the right to request access to the personal data we hold about you, and to obtain a copy of that data. If you have an account on our site, you can access certain personal data within your account. If not, you can contact us to request access to your data.
You may also lodge a complaint with the competent data protection supervisory authority if you feel that your privacy rights have been violated. We take appropriate measures to ensure that the privacy rights of European Economic Area (EEA) data subjects are adequately protected with respect to personal information we transfer outside the EEA. For more information about storage and international transfers, please refer to Section 14. To exercise any of these rights or for further assistance, you may contact us email@example.com
Provider may not always be able to fulfill all of your individual requests, depending on the situation and applicable laws. Please be aware that we reserve the right to decline requests that are manifestly unfounded or excessive, such as those that are repetitive in nature, and may charge a monetary fee in such cases. If you have unresolved concerns, you have the right to complain to an EU Supervisory Authority. The representative is UK Telecom Distribution LTD Customer Services, 99 Giles Street, Edinburgh, EH6 6BZ, United Kingdom
We have appointed a Data Protection Officer. You may contact the Data Protection Officer by sending an email to firstname.lastname@example.org or by writing to UK Telecom Distribution LTD Customer Services, 99 Giles Street, Edinburgh, EH6 6BZ, United Kingdom
Providing your information to us is optional, but it can impact our ability to offer the Service to you. For example, if you do not provide your complete personal information, we will not always be able to respond to your request in a timely manner.
If you have unresolved concerns, you have the right to complain to the EU Supervisory Authority. UK Telecom Distribution LTD Customer Services, 99 Giles Street, Edinburgh, EH6 6BZ, United Kingdom. We have appointed a Data Protection Officer. You may contact the Data Protection Officer by sending an email to email@example.com or by wirting to UK Telecom Distribution LTD Customer Services, 99 Giles Street, Edinburgh, EH6 6BZ, United Kingdom. Please refer to Section 3 for more information about data retention.
We process your information for the following purposes and legal bases:
(a) Operate our Site and Provide You with Our Services. Our use of the Information we collect is necessary to fulfill the contract between you and us. This includes responding to your inquiries, providing customer service, fulfilling product and service orders, resolving issues with your account or the Site, administering contests or promotions, and providing information to third parties at your request, such as SIM providers, matching services, or other SIM-related services. We also use this information to improve the Site, customize your experience, and pursue our legitimate interests as defined by art. 6(1) f of GDPR.
(b) Analyze and Aggregate Non-Personal Information. We use aggregate information and non-personal information to analyze user behavior and prepare reports for our legitimate interests as defined by art. 6(1) f of GDPR.
(d) Marketing & Communications. We use your information to contact you about maintaining your account or the Site, complying with your communication preferences, or providing other services as authorized by law. We may share your information with third parties, such as esim search editors, employers offering travel and SIM opportunities, or other SIM service providers.
(f) Profiling. We use your data to create your profile based on your eSIM searches and travel interests. We may suggest e-SIM providers or recommend your profile to employers or other individuals. We may also provide you with targeted ads based on your information. For more information about data retention, please refer to Section 3.
11. Notice to United Kingdom (“UK”) residents
Provider is compliant with the UK General Data Protection Regulation ("UK GDPR") and ensures that UK residents are able to exercise their rights in accordance with applicable law. The rights outlined in Section 10 of this policy also apply to UK residents. If you are a UK resident and have any questions please contact us by sending an email to firstname.lastname@example.org
12. Third Parties
Third-party websites may be linked on our Site and Provider may offer products and services that share information with third-party sites related to your eSIM search. It is important for you to review the privacy policies of these third-party sites and familiarize yourself with their privacy practices before providing your information, as we may not be responsible for their content or privacy practices.
13. Information Security
We have implemented reasonable technical, physical, and administrative measures to safeguard your information from unauthorized access, alteration, loss, misuse, or disclosure. However, please be aware that no method of transmission or electronic storage is completely secure, and we cannot guarantee the absolute security of your information. If you need to contact our Data Protection Officer, please send an email to email@example.com.
14. Children's Privacy
Our Site is designed for a general audience and is not intended for children under the age of 16. We do not knowingly collect any personal information from users under 16 years old. Our websites have mechanisms to prevent registration of minors under 16 years old. If you become aware that a child under 16 has provided us with their personal information, please contact us immediately so that we can remove the information from our system.
15. Storage and International Transfer
As a global company, we may store and process your information in locations outside of your country of residence, including in countries that may have different data protection and privacy regulations than those in your home country, such as the European Economic Area (EEA). However, we have taken steps to ensure that our affiliates and service providers comply with our high standards of data protection through strict contractual provisions, including Standard Contractual Clauses. By creating an account or providing us with your information, including personal information, you are consenting to the collection, storage, use, and processing of your information, including personal information, in the United States and other countries. We use tracking technologies as described above. If you would like to obtain a copy of the relevant transfer mechanism or additional information on these transfers, please contact us. Please note that while we take appropriate measures to protect your information, no method of transmission or storage is completely secure.
16. Notification Regarding Review and Updates.
17. California Residents
The following information is applicable only to individuals residing in California ("California consumers"). The California Consumer Privacy Act ("CCPA") requires that we provide California consumers with specific information regarding our handling of certain personal information collected online or offline. As defined by the CCPA, "personal information" includes any information that can identify, relate to, describe, be associated with, or linked to a particular consumer or household. The categories of personal information are listed below to the extent that they can identify, relate to, describe, be associated with, or linked to a particular consumer or household.
(a) Categories of Personal Information that We Collect and Disclose. We may collect and disclose the following categories of personal information from California consumers for business purposes: (1) name, contact information, and identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or similar identifiers); (2) customer records (such as electronic records containing personal information like name, signature, physical description, address, telephone number, education, employment, and employment history); (3) protected classifications (such as characteristics of protected classifications under California or federal law like race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information); (4) purchase history and tendencies (such as commercial information like records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); (5) usage data (such as internet or electronic network activity information, including but not limited to, browsing history, search history, and information regarding a California consumer's interaction with an Internet website, application, or advertisement); (6) geolocation data (such as precise geographic location information about a particular individual or device); (7) employment history (such as professional or employment-related information); (8) education information (such as information about education history or background); (9) Audio/Visual: audio, electronic, visual, thermal, olfactory, or similar information; and (10) profiles and inferences (such as inferences drawn from any of the information identified above to create a profile about a California consumer reflecting the California consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
The list above does not address our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
(b) California Consumer Rights. California law provides certain rights to California consumers and places limitations on certain business practices. One such right is the right to opt-out of the sale or sharing of personal information. The California Consumer Privacy Act (CCPA) defines personal information as any information that can be used to identify a person or their household. As a provider of services, we use your personal information to perform our contract with you and provide our services. We may also use data collection tools like cookies and web beacons and share your digital activity information with third parties to receive feedback about the performance of our marketing campaigns and website usage. However, some instances of data sharing may be considered a sale under CCPA. You can request us to stop sharing or selling your personal information, and we will honor your request for at least 12 months before asking you to opt back in. You can make this request personally or through an authorized agent, who will need to provide evidence of their agent status. Your request will be subject to an identification process, and we will not fulfill it unless you have provided all necessary information.
To make a Do Not Sell or Share my Personal Information request, please contact us at firstname.lastname@example.org
Nevada residents, please note that Provider will also honor your Do Not Sell or Share my Information request(s), in compliance with state privacy regulations.
(As a California consumer, you have the right to make certain requests related to your personal information. You can make these requests up to two times every 12 months without being charged. The requests include:
Deletion: You can ask us to delete your personal information that we have collected about you, except in certain situations where we need to retain the information for legal compliance, security, or debugging purposes.
Copy: You can request a copy of the specific pieces of personal information that we have collected about you in the past 12 months.
Right to Know: You can request that we provide you with certain information about how we have handled your personal information in the past 12 months. This includes the categories of personal information we have collected, the sources of that information, the purposes for collecting and selling the information, the categories of third parties with whom we have shared the information, and the categories of personal information that we have sold to each category of third party.
(c) Submitting Requests. You can submit a copy, deletion and right-to-know request online by sending a request through your account in case you are registered in the Site, by emailing us at email@example.com by utilizing any of the options made available to you by us throughout the Site for this purpose, or by contacting us at the toll free number in Contact Us.
(d) Incentives and Discrimination.
Under the CCPA, businesses cannot discriminate against California consumers who exercise their rights under the law. Additionally, if a business offers any financial incentives to consumers in exchange for their personal information, certain requirements must be met. The business may offer different prices, rates, or quality of goods or services based on the value of the consumer's data, as long as the difference is reasonable.
18. Contact Us
The Site is controlled and operated by Provider. Whether you access the services through any of our family Sites, you may contact Provider by any of the means in the Contact Us section on the Site. If your questions are not answered online, you are able to email us at firstname.lastname@example.org, write to us at UK Telecom Distribution LTD Customer Services, 99 Giles Street, Edinburgh, EH6 6BZ, United Kingdom