SIMLESS TRAVEL E-SIM Privacy Policy

v1.1

This Privacy Policy applies to the products and services provided by SIMLESS TRAVEL E-SIM (referred to as “SIMLESS TRAVEL E-SIM”, “we”, “us”, or “our”). We are committed to complying with applicable privacy and data protection laws and regulations. We apply appropriate technical and organizational safeguards in line with legal requirements and recognized industry standards to protect the personal information of individuals who use our products or services (referred to as “you”, “your”, or “users”).

This Privacy Policy explains:

  1. What personal information we collect and how we use it
  2. How we use cookies and similar technologies
  3. How we share, transfer, and disclose personal information
  4. How we protect personal information
  5. Your rights
  6. International transfers of personal information
  7. How we handle children’s personal information
  8. How this policy is updated
  9. How to contact us

Please read this Privacy Policy carefully before using our products or services. It is especially important that you understand and agree to our collection, use, storage, and sharing of your information, as well as any clauses relating to limitations or exclusions of liability. If you do not agree with any part of this Privacy Policy, you may choose not to use our products or services (unless otherwise stated, “use of services” includes use of our website).

Minors should review this Privacy Policy with a parent or legal guardian and decide whether to agree under their guidance. By ticking the “I Agree” box or by continuing to use any of our products or services, you expressly confirm that you have read and agreed to this Privacy Policy and consent to our collection and handling of your personal information as described.

This Privacy Policy and our “User Agreement” together form a single agreement. If there is any conflict between them, this Privacy Policy will prevail.


1. How and What We Collect and Use Your Personal Information

We collect and use user information primarily to provide a secure, smooth, efficient, and customized service experience. In general:

  • To deliver core services, we must collect and use certain necessary information.
  • To deliver additional features, you may choose whether to authorize the collection and use of certain information.

We may collect and use your personal data to:

  • send you relevant information;
  • respond to your inquiries;
  • perform statistical analysis;
  • meet regulatory obligations;
  • pursue or defend legal claims;
  • improve customer service and enhance how our services operate (including tailoring our website to your needs);
  • inform you about our services across our business areas; and/or
  • carry out marketing activities that are personalized and relevant to you.

If you refuse to provide necessary information, you may not be able to use some or all functions of our products/services.

1.1 Personal Information You Must Provide or Authorize for Core Services

(a) Account Registration

To use our products and services, you may need to create an account. When registering, you must provide an email address for verification. We will send a verification code to confirm the validity of your account.

(b) Product/Service Display, Compatibility, and Security

When you use our services, we may automatically collect and store usage data as network log information for purposes such as identifying abnormal account activity, understanding product compatibility, and improving the relevance of page displays and search results. This may include:

  • Device information: such as device model, operating system version, device settings, unique device identifiers, and device environment/hardware-software characteristics. We may also collect device location-related information (such as GPS location authorized by you, WLAN access points, Bluetooth, and base station information). “Unique device identifiers” may include IMEI, IMSI, AndroidID, IDFA, OPENUDID, GUID, or other identifiers that can be used to recognize a device.
  • Service log information: such as browsing and clicks, search queries, transactions, after-sales requests, sharing actions, IP address, browser type, telecom operator, language, and date/time of access.

Device information and service logs may not directly identify you as a specific individual on their own. If we combine such information with other data that can identify you, we will treat it as personal information and apply appropriate protections. Unless we have your authorization or the law allows otherwise, we will anonymize or de-identify such data where appropriate.

(c) Traffic Products and Services

When you use our data/traffic products, we may collect your bound traffic card ICCID, destination, activation time, expiration time, and package usage information.

(d) Transaction and Service Security

To maintain normal operations, enhance service experience, and protect account security, we may collect information regarding your interactions with our software, services, products, or webpages (including computer/platform/device/connection information, client performance information, error reports, device features, bandwidth, browsing statistics, browser type, and usage statistics). We may also send service updates, failure notices, and related rights/obligations information through in-app notifications, SMS, or similar communications.

(e) Purchasing Products or Services

When you purchase products or services, we may collect order-related information you provide, such as recipient name, phone number, address/shipping details, and payment method. We use this information to receive, process, and deliver orders, issue invoices (if applicable), and notify you about order status.

If you request an invoice, you may need to provide invoicing details and the mailing recipient’s name, address, and phone number for delivery.

(f) Customer Support

When you contact us for support, complaints, appeals, or inquiries, we may request information such as your name, phone number, email, or other contact methods to verify account security, communicate with you, and resolve issues. If you decline to provide relevant details, we may not be able to respond effectively or promptly.

To help resolve issues and maintain records, we may store communications and related content between you and us, including account information, order information, and other supporting materials you provide.

(g) Marketing

We may use your email address to send marketing communications (such as coupons, discounts, and promotional campaigns). By creating an account, you are generally considered to have agreed to receive such communications.

You may opt out at any time by clicking the “Unsubscribe” link in marketing emails or by contacting customer service. If you opt out, you may no longer receive marketing communications, but this will not affect your ability to access our main products or services.

We may also collect your browsing activity on our website for marketing purposes (to understand preferences and recommend relevant products/services). We will only collect such browsing activity after you successfully sign in to your account.

[For users who are Japanese residents] You may opt out by contacting us (or via another written method). Please note that if we cannot collect information necessary for a specific function, we may not be able to provide the related products/services.

1.2 Optional Personal Information You May Choose to Authorize

(a) Camera Permission (Scanning Feature)

If you enable camera access, you can use scanning functions to automatically recognize and input card numbers.

(b) Location Permission

If you enable location access, we may collect precise or general location information to determine your destination and automatically display products/services available for that destination.

You may turn permissions on or off at any time in your device settings. Turning off a permission will stop future collection for that feature, but it will not affect processing already completed based on your prior authorization.

This Privacy Policy does not apply to (i) data collected when you access third-party services (including third-party websites) through our services, or (ii) data collected directly by other companies or organizations that promote services on our platform.

1.3 When We May Collect and Use Information Without Your Authorization

We may collect and use personal information without your consent where permitted by applicable law, including:

  1. national security or defense;
  2. public safety, public health, or major public interest;
  3. criminal investigations, prosecutions, trials, or enforcement;
  4. protection of life or property where consent is difficult to obtain;
  5. information you have publicly disclosed;
  6. information obtained from lawful public sources;
  7. fulfilling a contract at your request;
  8. maintaining safe and stable operation of our products/services;
  9. other circumstances permitted by law.

1.4 Accessing Third-Party Services Through SIMLESS TRAVEL E-SIM

1.4.1

Some services may be provided by authorized partners to help us offer better quality and broader service. We may share limited information with partners to deliver customer service and improve user experience. You may opt out by deleting cookies or contacting us.

1.4.2

Partners may also share information with us so we can provide core functions such as displaying relevant discounts based on location. We require confidentiality and security measures for such partners.

1.5 Advertising/Promotion on SIMLESS TRAVEL E-SIM

We may share aggregated, anonymized, or de-identified analytics with advertising partners to help them understand performance. We do not share identifying personal information without consent.

[For users who are Japanese residents] Without your explicit consent, we will not share information in a way that could identify you by combining it with other data.


2. Cookies and Similar Technologies

We may store small data files called cookies on your device to ensure our services operate properly. Cookies may store identifiers and preferences. We only use cookies for the purposes described in this Privacy Policy. You can manage or delete cookies through your browser/device settings.


3. How We Share, Transfer, and Disclose Personal Information

Unless otherwise stated in this Privacy Policy, we do not share, transfer, or publicly disclose your personal information without your valid and explicit permission.

3.1 Sharing

We may share personal information only in these cases:

  • With your explicit consent;
  • When required by law or for legal processes;
  • With our subsidiaries/affiliates under common control to provide services;
  • With authorized partners to perform specific tasks and provide core functions (e.g., payments, infrastructure, analytics) under confidentiality obligations;
  • With marketing service providers (e.g., Mailchimp) to manage email campaigns, and you may opt out anytime.

3.2 Transfer

We do not transfer your personal information except with your explicit consent or in corporate transactions (e.g., merger, acquisition, liquidation), where the receiving entity must continue to protect your information under this policy or obtain your consent again.

Our servers used to restore personal information are located in Singapore, and your information may be transferred there for restoration purposes. We protect transmissions using encryption such as SSL or TLS.

3.3 Public Disclosure

We disclose personal information only with your consent or where required by law.

3.4 Legal Exceptions

Where permitted by law, we may share/transfer/disclose personal information without prior consent for national security, public safety, public health, criminal justice, protection of vital interests, information you made public, or information from lawful public sources.


4. How We Protect Your Personal Information

We take appropriate security measures and limit access to authorized staff and trusted partners only. We retain data only as long as necessary for the purposes described, unless the law requires longer retention.

If a security incident occurs, we will notify you as required by law and take necessary remediation steps. We may notify you via SMS, phone, push notifications, or public notice where individual notification is not feasible.


5. Your Rights

5.1 Access and Correction

You may request access to and correction of certain information. Some data (such as device data used for security and service optimization) may not be directly accessible. You may contact us to request deletion or anonymization where appropriate.

5.2 Deletion

You may request deletion of your personal information where permitted by law. If approved, we will also request that relevant recipients delete the data, unless otherwise permitted or required. Backup systems may be updated on a delay.

5.3 Withdrawing Consent

You may withdraw consent by changing device permissions, unsubscribing from emails, deleting data, or adjusting privacy settings. Withdrawal does not affect prior processing based on your earlier consent.


6. International Transfers

Your information may be stored or accessed in jurisdictions outside your country/region due to our global infrastructure. Where required, we take steps such as requesting consent, applying de-identification, and implementing security safeguards to ensure adequate protection and legal compliance.


7. Children’s Personal Information

Our services are intended mainly for adults. Children should not create accounts without parental/guardian consent. We generally treat individuals under 14 as children. If we discover data collected from a child without verifiable guardian consent, we will delete it as soon as reasonably possible.

[For users who are Japanese residents] We do not collect personal information from children under 16 without explicit guardian consent.


8. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, user feedback, or legal requirements. If there are material changes, we will display a prominent notice or notify you directly before changes take effect.


9. Contact Us

If you have questions or requests about this Privacy Policy, please contact our customer service via the “Contact Us” page in your account section. We generally respond within 15 business days.

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