Effective Date: June 3, 2024
AIRGSM PTE. LTD., doing business as eSIMPlus ( www.eSIMPlus.com ) (“eSIMPlus” or “we”), recognizes the importance of your privacy. This Privacy Policy describes how we collect, use, share, and protect your personal information, also known as personal data. This Privacy Policy also explains your rights and choices regarding your personal information, and how you can contact us with questions.
By registering for an account or otherwise using or accessing any eSIMPlus website, application, product, software, tool, data feed, and/or service (collectively, the “Services”), you understand and agree to the terms of this policy.
This Privacy Notice explains how we collect, use, disclose, retain, and protect your personal information. Please read this Privacy Policy carefully.
Index:
1. Scope of application of this Privacy Policy
2. How We Collect, Disclose, and Use Personal Information
3. Information We Collect
4. Data retention
5. How we use information
6. How We Share Personal Information
7. Your Rights
No. 8. Data Transmission & International Data Transmission
9. Security
10. Changes to this Policy
11. Children
12. Contact information
13. Additional Information for California Residents
1. Scope of application of this Privacy Policy
This Privacy Policy applies to users of eSIMPlus services globally, including users of eSIMPlus’s mobile applications, Partner Platform, websites, features, or other services who interact (online and offline) with eSIMPlus, its employees, and job seekers (“Services”).
This Privacy Policy describes how eSIMPlus collects and uses data and applies to all eSIMPlus users globally, unless they use a service covered by a different privacy notice. This Privacy Policy specifically applies to:
End Users: Individuals who use and interact directly with the Service through their eSIMPlus account for personal use.
Business Users: eSIMPlus provides services to organizations (“Business Users”) who directly and indirectly provide End Customers’ personal information to us, in connection with such Business Users’ own business operations.
End Customers: Individuals who receive services ordered by other eSIMPlus account holders, for example, when you work, or otherwise transact with, a Business User.
Job Seekers: Individuals who submit a job application to eSIMPlus.
2. How we collect, disclose, and use personal information
We collect information about you in a variety of ways depending on how you interact with us and our Services, including:
Directly from you when you provide information to us, such as when you register for an account, sign up to receive mailings from us, place an order, make a purchase, or contact us by phone, email, or otherwise.
Automatically, by means of 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 consent.
From other sources, including, for example, our affiliates, business partners, service providers, online social networks, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
eSIMPlus classifies data and information systems according to legal requirements, sensitivity, and business necessity to ensure that information is appropriately protected. A “data controller” is an organization that determines the purposes and means of data processing. A “data processor” is an organization that processes personal information on behalf of, and under the instructions of, a controller.
eSIMPlus as data controller
eSIMPlus assumes the role of data controller when it determines the purposes and means of processing personal data. As a data controller, eSIMPlus is responsible for ensuring that personal data is processed in accordance with applicable data protection laws. eSIMPlus‘s functions as data controller include:
Direct Registration: eSIMPlus is a data controller when a user registers directly with the service. This applies to both:
B2C Context: End users sign up directly for eSIMPlus‘s service.
B2B Context: Business users or End Customers register directly with eSIMPlus.
Main activities:
Providing Services: Using data to provide eSIMPlus products and services.
Fraud Prevention: Monitor and detect fraudulent transactions and activities.
Legal Compliance: Comply with applicable financial, legal, and regulatory obligations.
Service Enhancement: Develop and improve products and services based on data analysis.
Processing of job applications: Processing of personal data from job applications.
eSIMPlus as a data processor
In situations where eSIMPlus provides services on behalf of and at the direction of Business Users, we act as a data processor. This includes situations such as:
B2B Context for End Customers: eSIMPlus acts as a data processor for End Customer related data of Business Users in a B2B environment.
Service execution for Business Users: Follow instructions from Business Users, such as account creation and eSIM distribution to End Customers.
As a data processor, we advise users to consult the privacy policy of the respective data controller (Business User) for information on how their data is processed and protected. eSIMPlus strictly adheres to the instructions provided by the data controller and is committed to ensuring the confidentiality and security of the data processed in accordance with applicable data protection laws and contractual obligations.