eSIMsmart

eSIMsmart takes the privacy of its Customers seriously; maintaining your trust is paramount to us. This Statement discloses the information practices for eSIMsmart and our affiliates, from what type of information about our customers is gathered, to how the information is used, shared or otherwise processed.

From time to time, we may supplement this Statement with additional information relating to a particular interaction we have with you.

Topics

1. What information do we collect about you?
2. How will we use the information about you?
   1. Fulfilling your Request
   2. Personalising your Experience on our websites
   3. Providing Support
   4. Marketing
   5. Recruitment
   6. Monitoring or Recording of Calls, Chats and Other Interactions
   7. Mobile Applications and Social Media
   8. Protect the Rights and Property of eSIMsmart and Others
   9. Information for Business Partners
   10. Sharing of Personal Information and International Transfers
3. Information Security and Accuracy
4. Retention
5. Cookies
6. Online Advertising
7. Links to Non-eSIMsmart Websites and Third Party Applications
8. Notification of Changes
9. Access to Your Information and Corrections
10. How to Contact us

1 What information do we collect about you?

You may choose to give us personal information directly in a variety of situations. For example, you may want to give us your name and contact information to communicate with you, to order a product, to process an order, to register for a service, to provide you with a subscription, or to do business with us if you are a supplier or a business partner. You may also provide your bank or credit card details to buy something from us or may share a description of your education and work experience in connection with a job opening at eSIMsmart for which you wish to be considered. If you tell us that you do not want us to use your information to make further contact with you beyond fulfilling your request, we will respect your wishes.

We may also collect information relating to your use of our websites through the use of various technologies. For details regarding the technologies we employ, see Cookies below.

2 How will we use the information about you?

The following paragraphs describe in more detail how eSIMsmart may use your personal information.

2.1 Fulfilling your Request

If you request something from eSIMsmart, for example, a product or service, a call back, or specific marketing materials, we will use the information you provide to fulfil your request. To help us do this, we may share information with others, for instance, eSIMsmart's business partners, financial institutions, shipping companies, or postal or government authorities, such as Customs authorities, involved in fulfilment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

2.2 Personalising your Experience on our websites

We may use information we collect about you to provide you with a personalised experience on our websites, such as providing you with content in which you may be interested and making navigation on our sites easier.

2.3 Providing Support

We may use your personal information to support products or services you have obtained from us, such as notifying you of a product update or fix.

We also provide “Live Chat” sessions on our websites to assist you while you’re navigating through our sites; we will use personal information you provide via these sessions in accordance with this Privacy Statement.

2.4 Marketing

The information you provide to eSIMsmart, as well as the information we have collected about you indirectly, may be used by eSIMsmart for marketing purposes. Before we do so, however, we will offer you the opportunity to choose whether or to have your information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we call you, by contacting us directly (please refer to our contact details below).

Some of our offerings may be co-branded, that is sponsored by both eSIMsmart and third parties. If you sign up for these offerings, be aware that your information may also be collected by and shared with those third parties. We encourage you to familiarise yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.

2.5 Recruitment

In connection with a job application or inquiry, whether advertised on an eSIMsmart website or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout eSIMsmart in order to address your inquiry or consider you for employment purposes. Unless you tell us not to do so, we may keep the information for future consideration.

2.6 Monitoring or Recording of Calls, Chats and Other Interactions

Certain transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is eSIMsmart's general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

2.7 Mobile Applications and Social Media

eSIMsmart makes available mobile applications for download from various mobile application marketplaces. eSIMsmart also provides social media tools on some of its websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When downloading and using these applications or registering to use these social media tools, you may be asked to provide certain personal information. Registration information will be subject to and protected in accordance with this Privacy Statement, except for the information that is automatically made available to other participants as part of your profile. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. Read those supplemental statements to understand what the tools and applications may do.

Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Statement. Rather, such content is subject to the Terms of Use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools or get help to do so. Please refer to them to better understand yours, eSIMsmart's, and other parties' rights and obligations with regard to such content. You should be aware that the content you post on any such social media platforms may be made broadly available to others inside and outside eSIMsmart.

2.8 Protect the Rights and Property of eSIMsmart and Others

We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our websites.

2.9 Information for Business Partners

If you represent a eSIMsmart business partner, you may visit eSIMsmart websites intended specifically for eSIMsmart business partners. We may use information provided on that site to administer and develop our business relationship with you, the business partner you represent, and eSIMsmart business partners generally. For instance, this may involve using your information to send you details of eSIMsmart business partner programs. It may also include sharing certain information with other business partners (subject to any confidentiality obligations that may exist), or eSIMsmart customers or prospects. In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes.

2.10 Sharing of Personal Information and International Transfers

eSIMsmart is a global organisation with business processes, management structures and technical systems that cross borders. As such, we may share information about you within eSIMsmart and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Statement. Our Privacy Statement and our practices are designed to provide a globally consistent level of protection for personal information all over the world. This means that even in countries whose laws provide for less protection for your information, eSIMsmart will still handle your information in the manner described here.

In some cases, eSIMsmart uses suppliers located in various countries to collect, use, analyse, and otherwise process information on its behalf. It is eSIMsmart's practice to require such suppliers to handle information in a manner consistent with eSIMsmart's policies.

From time to time, we may disclose information that identifies you at an individual level and which we collected on our websites to other non-eSIMsmart entities that are not acting as our suppliers, such as our business partners. Except as described in this Privacy Statement, we will only do so with your prior consent. We do not sell or lease such information however.

Circumstances may arise where, whether for strategic or other business reasons, eSIMsmart decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the transfer of personal information to the purchaser. It is eSIMsmart’s practice to seek appropriate protection for information in these types of transactions.

When transferring your information outside of the country of collection for the purposes identified above, eSIMsmart complies with applicable law. For data originating from a European Union member state, eSIMsmart uses a variety of data transfer mechanisms (including standard contractual clauses) for this purpose.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process.

3 Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy. eSIMsmart implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorised access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorised access, use and disclosure.

4 Retention

We will retain your registration information for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your registration information to provide you services please contact us at the details below. We will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5 Cookies

We collect information from your visits to our websites to help us gather statistics about usage and effectiveness, personalise your experience, and tailor our interactions with you. We do so through the use of various technologies, including cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and then above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

We may also include Web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.

Some of our business partners set Web beacons and cookies on our site. In addition, third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring website addresses, and, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site. We do not control these third party tracking technologies.

6 Online Advertising

eSIMsmart does not deliver third party online advertisements on our websites but we advertise our products and services on others' websites. Please familiarise yourself with those website operators' or network advertisers' privacy policies to understand their practices relating to advertising, including what type of information they may collect about your Internet usage.

We have also engaged with certain third parties to manage some of our advertising on other sites. These third parties may use cookies and Web beacons to collect information (such as your IP address) about your activities on eSIMsmart's and others' websites to provide you targeted eSIMsmart advertisements based upon your interests. Those eSIMsmart advertisements that are targeted to you will be identified with the AdChoices icon. You can click on the icon in the advertisements itself to manage your preferences.

7 Links to Non-eSIMsmart Websites and Third Party Applications

To allow you to interact with other websites on which you may have accounts (such as Facebook and other social media sites) or join communities on such sites, we may provide links or embed third-party applications that allow you to login, post content or join communities from our websites.

We may also provide you with general links to non-eSIMsmart websites. Your use of these links and applications is subject to the third parties’ privacy policies, and you should become familiar with the third party sites' privacy policies before using the links or applications.

eSIMsmart is not responsible for the privacy practices or the content of those other websites.

8 Notification of Changes

We will post a notice at the top of this page notifying users when this Privacy Statement is updated or modified in a material way. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you, and you will have a choice as to whether or not we can use your personal information in such a way.

9 Access to Your Information and Corrections

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact us on the details below.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

10 How to Contact us

Please contact us if you have any questions about our Privacy Statement or information we hold about you:

The Data Protection Officer
eSIMSmart
Park House
Clifton Park
York
YO30 5PB, UK

e: info@esimsmart.com

t: +44(0)1904 610 610

Before eSIMsmart is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will contact you within 30 days of your request.

If you are unsatisfied with our response, you are entitled to raise your concern with the Information Commissioner’s Office (ICO): www.ico.org.uk/concerns/