Privacy Policy

Effective date: 3 June 2024

EsimforAll (esimforall.net) , recognizes the importance of your privacy. This Privacy Policy describes how we collect, process, share and protect your personal information, also known as personal data. This Privacy Policy also informs you of your rights and choices with respect to your personal information and how you can contact us to get answers to your questions.

By registering for an account or otherwise using or visiting any Esimforall website, application, product, software, tools, data feeds and/or services (collectively, the “Service”), you understand and agree to the terms of this policy.

This Privacy Policy explains how we collect, process, disclose, store and protect your personal information. Please read this Privacy Policy carefully.

Summary:

1. Applicability of this Privacy Policy
2. How we collect, disclose and process personal information
3. Esimforall as data controller
4. Esimforall as data controller
5. How we use personal information
6. How we share personal information
7. Your rights
8. Data transfer and international data transfer
9. Security
10. Changes to this information
11. Children
12. Contact information

1. Applicability of this Privacy Policy

This Privacy Policy applies to users of Esimforall services globally, including users of Esimforall mobile applications, partner platform, websites, features or other services, interactions (online and offline) with Esimforall (the "Services").

This Privacy Policy describes how Esimforall collects and processes data and applies to all Esimforall users globally, unless they use a service covered by

a separate privacy policy. This Privacy Policy applies specifically to:

End users:

individuals who use and interact directly with the Services through their Esimforall account for personal use.

2. How we collect, disclose and process personal information

We collect information about you in a variety of ways, depending on how you interact with us and our Services, such as:

Directly when you provide it, such as when you register for an account, sign up to receive communications from us, place an order, make a purchase, or contact us by phone, email, or otherwise.

Automatically, using cookies, server logs, and other similar technologies when you interact with us through our Services and/or via email, where permitted by law or with your prior consent.

From other sources, including, for example, our affiliates, business partners, service providers, online social media networks and other third parties, or from publicly available sources. For example, if you apply for a job or become an employee, we may conduct a background check.

Esimforall classifies data and information systems in accordance with legal requirements, sensitivity and business criticality in order to ensure that information is provided with the appropriate level of protection. The "data controller" is the entity that determines the purposes and means of data processing. The "processor" is an entity that acts on behalf of and under the instructions of a data controller in the processing of personal data.

3. Esimforall as data controller

Esimforall assumes the role of data controller when it determines the purposes and means of the processing of personal data. As a data controller, Esimforall is responsible for ensuring that personal data is processed in accordance with applicable data protection laws. The activities of Esimforall as a data controller include:

Direct registration:

Esimforall is the data controller when users register directly to the service. This applies to both:

B2C contexts: end users who register directly to Esimforall services.

Main activities:

Service provision: data processing to provide products and services of Esimforall.
Fraud prevention: monitoring and detection of fraudulent transactions and activities.
Legal Compliance: meeting applicable financial, legal and regulatory obligations.
development and improvement of products and services based on data analysis.

About the data:

Necessary online monitoring technologies

We use cookies and clear GIFs. "Cookies" are small pieces of information that a website sends to a computer's hard drive while it is being

viewed a website. Clear GIFs refer to pixels loaded by your browser when you access a website.

These tracking technologies may collect information about your browser type, operating system, Internet Protocol (IP) address (a number that is assigned to your computer).

automatically to a computer when using the Internet), domain name, click activity, website

reference and/or date/time of visitors.

We have a legitimate interest in operating our website in

efficient way.

4. Esimforall as data controller

We only retain your personal information for as long as necessary to fulfil the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. How we use personal information

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our websites.
To provide products and services or to handle returns.
To improve our services and product offerings.
To simplify the payment process.
To conduct analysis.
To communicate with you, for example to respond to and/or follow up on your requests, questions, problems or feedback.
To send you marketing and promotional materials, including information about our products, services, sales or promotions or those of our business partners.
To detect and protect against harmful, deceptive, fraudulent or illegal activities, including violations of our policies and terms and conditions, security incidents and harm to the rights, property or safety of our company and our users, employees or others.
To debug, identify and repair errors that impair the existing intended functionality of our website and services.
To comply with our legal or regulatory obligations, to establish or exercise our rights and to defend ourselves against legal claims.
For internal administrative purposes, as well as to manage our relationships.
For other purposes to which you may consent (from time to time).

While the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete a purchase online, we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in retaining it after the transaction has been completed so that we can quickly and easily answer any questions you may have about your order. Accordingly, our collection and processing of your information is based in different contexts on your consent, our need to perform a contract, our obligations under the law, and/or our legitimate interest in conducting our business.

6. How we share personal information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

Affiliates and Acquisitions: Sharing Information with them our affiliated companies (e.g. parent company, subsidiaries, subsidiaries, joints venture or other companies under common control). If another company acquires, or plans to acquire, our company, business or assets, we will share the information Also with company account, even during the negotiation phase.
Other Disclosures Without Your Consent: We may disclose information in response to a subpoena, warrant or court order, or in connection with any legal proceeding, or to comply with applicable laws. We may also share your information to establish or exercise our rights, to defend ourselves against a legal claim, to investigate, prevent or take action regarding possible illegal activities, suspected fraud, safety of persons or property, or violations of our policies, or to comply with your request to ship products or provide services to you through a third-party intermediary.
Promotional Partners: We may offer promotions with third-party partners. If you decide to participate in a promotion sponsored by a third-party partner, the information you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
Service Providers: We may share your information with service providers. Among other things, service providers help us administer our website and provide services for the effective operation of our business, provide technical support, process payments, and assist in fulfilling orders.
Other disclosures with your consent: We may disclose your information to other third parties when we have your consent or direction to do so.

7. Your rights

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

Access your data: the right to request that we disclose to you the personal information that we collect, use or disclose about you and information about our data practices. In some limited circumstances, you may also request to receive access to your personal information in a portable and machine-readable format.
Verify and request rectification: The right to request that we correct inaccurate personal information that we maintain about you. We rely on you to update and correct your personal information. Our website allows you to change or delete your account profile. If our website does not allow you to update or correct certain information, you can contact us at the address described below to request that we change your information. Please note that we may retain historical information in our backup files to the extent permitted by law.
Delete or otherwise remove your personal information: the right to request that we delete the personal information we have collected about you.
Withdraw consent at any time: right to withdraw consent if you have previously given consent to the processing of your personal data.
Object to the processing of your personal data: the right to object to the processing of your personal data if the processing is carried out on a legal basis other than consent.
Online Tracking: We do not currently recognize the "Do Not Track" signal.

Please note that not all of the rights described above are absolute and do not apply in all circumstances. In some cases, we may limit or deny your request because the law allows or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals for exercising their privacy rights under applicable law.

Please see this section to learn more about your specific rights. To submit a request to exercise any of the rights described above or to appeal a decision we have made in relation to a data subject rights request, please contact us using the contact information below.

Please note that, as required by law, we will ask you to prove your identity. Depending on your request, we will ask you for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed statement confirming your identity. Upon a request, we will make reasonable efforts to provide, correct, or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a signed document indicating that you are authorized to act on behalf of another person.

How do I unsubscribe from marketing emails?

If you have any questions about how to opt out of Esimforall marketing communications, please feel free to contact us at support@esimforall.com.

How can I delete my account?

Please note that in any case, we may need to verify your identity and your relationship with us before we can proceed with your request.

When does Esimforall continue to process data after receiving a request for deletion or objection to processing?

In certain circumstances, Esimforall may be required by law to retain and process your personal data even after a request for deletion or an objection to the processing. For example, Esimforall is required to retain certain personal information to comply with legal obligations under Know Your Customer (KYC) and payment transaction details.

8. Data Transfer and International Data Transfer

The Service is owned by Esimforall and is accessible in Europe and abroad. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws of your country. However, where possible, we take steps to treat personal information using the same privacy principles applicable under the law of the country in which we first received your information. By submitting your personal information to us, you agree to the transfer, storage and processing of your information in a country other than your country of residence, including, but not limited to, the United States. If you would like more information about our attempts to apply privacy principles applicable in one jurisdiction to data when it is transferred to another jurisdiction, you can contact us using the contact information set out below.

9. Security

We follow generally accepted industry standards to protect your personal information. No method of transmission over the Internet, mobile technology, or method of electronic storage is completely secure. Therefore, while we strive to maintain physical, electronic, and procedural safeguards to protect the confidentiality of information we collect online, we cannot guarantee its absolute security.

Esimforall users remain responsible for the security of their password and credentials. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any account you may have with us has been compromised), please notify us immediately of the problem by contacting us at support@esimforall.com.

10. Changes to this information

We reserve the right to change the terms of this Privacy Policy at any time. If there are material changes to this policy or in the way we treat your personal information, we will notify you by prominently posting a notice of such changes here or on our home page or by sending you an email. We encourage you to review this policy each time you visit one of our websites or applications. Our privacy policy includes an “effective” and “last updated” date. The “effective” date refers to the date the current version was effective. The “last updated” date refers to the date the current version was last substantially changed.

11. Children

Our Services are not intended for children under the age of 13, and we do not knowingly collect personal information from unemancipated minors under the age of 16, without parental consent. Children under the age of 13 should not provide their personal information to us.

12. Contact information

If you have any questions, comments, complaints or requests regarding our privacy practices or if you need to access this Privacy Policy in an alternative format because of a disability, please contact us at the appropriate address below. We will try to respond to your requests and provide you with additional privacy-related information.

support@esimforall.com

Category of personal information	Category of recipients
	Disclosures for commercial purposes	Sharing for advertising behavioral multi-context
	Affiliates or branches
	Commercial collaborators
	Data analytics providers
	Internet Service Providers
Identifiers: may include your real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Joint Marketing Partners Operating Systems and Platforms Other service providers	Advertising networks
	Payment Management Entities and Financial Institutions
	Professional services organizations, including accountants and law firms
	Social network

Category of personal information	Category of recipients
Government-issued identification: This may include your Social Security number, your driver's license number, your state-issued identification number, or your passport number.	Network Operators (where eKYC is required) Professional services organizations, including accountants and law firms
Financial Information: may include bank account number, credit card number, debit card number and other financial information.	Operating Systems and Platforms Payment Management Entities and Financial Institutions Professional services organizations, including accountants and law firms
Characteristics of protected classifications: may include age, sex, origin, ethnicity, physical or mental handicap, etc.	Network Operators (where eKYC is required) Professional services organizations, including accountants and law firms
Commercial information: may include information about products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies.	Affiliates or branches Commercial collaborators FData analytics providers Internet Service Providers Joint Marketing Partners Operating Systems and Platforms Altri service providers Payment Management Entities and Financial Institutions Professional services organizations, including

Category of personal information	Category of recipients
	auditors and law firms Social network
Internet or other electronic network activity information: This may include browsing history, search history, and information about an individual's interaction with an Internet website, application, or advertisement.	Data Analysis Providers	Advertising networks
Professional or employment-related information	Affiliates or branches Commercial collaborators Operating Systems and Platforms Other service providers Professional services organizations, including accountants and law firms
Non-public education information (as defined in the Family Educational Rights and Privacy Act)	Affiliates or branches Commercial collaborators Operating Systems and Platforms Other service providers Professional services organizations, including accountants and law firms