Introduction

This privacy policy (“Notice”) is intended to inform you about how your Personal Data will be handled by eSIM70 (“eSIM70” “we” “us” or “our”) and sets out the information including personal information detailed below relating to you or which you provide to us (“Personal Data”) that will be collected and processed by eSIM70 and/or on its behalf by its third party service providers when you contact us through our channels, such as our application, website or, once you have contracted for our services. We are required to give you this information, including to inform you about your data protection rights, under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Does eSIM70 comply with data protection laws?

eSIM70 takes its data protection obligations seriously and will never share personal data with any third parties without the proper legal basis. We are committed to compliance with data protection and privacy regulations globally, including GDPR, UK data protection laws, and relevant privacy frameworks in North America, Australia, and Latin America, with privacy by design integrated into all our services.

eSIM70 as data controller

eSIM70 is committed to respecting your fundamental right to the protection of your Personal Data and this Notice is intended to inform you about the processing of your Personal Data by us.

Types of Personal Data we process about you

Category of Personal Data	Details
Website Usage and Device Data: When you visit our application, or our website.	Your visits and interactions with our website including which webpages you visit, time and date of access, what you click on, when you perform these actions; Your device data including your IP address, location data, device type and language, browser type and other related information; and Any linked websites that you access through the website.
Most of this Personal Data is collected using cookies on the Website.
Customer Data: When you purchase an e-SIM or data plan.	Full name; title, country of residence; current location; residential address; network provider; telephone number; payment information; e-mail address; device type (e.g. make and model); a copy of your passport, driving licence or similar documentation for identification (where necessary); and other details relating to you when you interact with us regarding the purchase of an e-SIM.

Sources of your Personal Data

During the course of our contractual relationship with you or when you visit our website or application, we will collect Personal Data either: (1) directly from you, or (2) indirectly from third parties (for example, once you have contracted for our services, through our affiliates or travel agencies).

For what purpose and on what legal basis do we process personal data?

We have set out in the below table the key context upon which (“Legal Basis”) we process your Personal Data. We also explain how (“Nature of Processing”) and why (“Purposes”) we obtain and collect your Personal Data.

Legal Basis	Nature of Processing and Purposes	Categories of Personal Data
Compliance with a Legal Obligation	• eSIM70 may process your Personal Data where it is necessary to comply with legal obligations to which we are subject under European Union and/or applicable laws, including but not limited to safeguarding and complying with law enforcement requests.	Customer Data Website Data
Performance of a Contract	• To provide you with access to the website and to allow you to use the website.
• To manage the purchase of the e-SIM or data plan that we sell on our website and the payment relating to such products.
• To calculate and issue charges for services provided to you.
• To review and attend to customer incidents, queries, complaints or requests relating to our products and services.
• To manage and perform any after-sales services.
• To manage your registration as a user of our website and/or application, as well as to allow your access to the eSIM70’s private user area	Customer Data Website Data
Legitimate Interest	• To facilitate the use of your e-SIM or data plan, including the administration of your account, and to provide customer care to you.
• To better understand how our customers use our website in order to improve it. To tailor products and services to you and, if you consent to direct marketing, to tailor direct marketing.
• To monitor against and prevent cyber-security issues and unauthorized use of our information, IT systems and/or equipment.
• To streamline our business processes by using external platforms;
• To conduct internal business reviews and, if necessary, contact the customer in the event that fraud or identity theft is detected or there are reasonable suspicions of fraud, identity theft or illegal activity.
• To record calls for training purposes and to improve our customer service.
• To conduct periodic reviews of our services and carry out satisfaction surveys to evaluate and improve the quality of the service we provide.
• To carry out any other activities necessary to the running of our business, including system testing, network monitoring, staff training, and quality control.	Customer Data Website Data

With whom do we share Personal Data?

Depending on the Purpose for which we process your Personal Data, we may share such Personal Data with some or all of the following recipients to the extent necessary:

eSIM70 internal/ intra-group entities: Internal departments and services (such as our sales department, marketing department or IT department).
Telecommunications service providers: Service providers located in the appropriate jurisdiction for which the e-SIM service was purchased.
Regulatory authorities and law enforcement agencies: Where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request, such as the Revenue Commissioners, Department of Social Protection, the Data Protection Commission, Workplace Relations Commission, the Irish courts, An Garda Síochána or any other applicable authorities.
Third party advisors/ professionals: Professional advisors who provide professional services to us e.g. consultants, legal advisors.
Third party service providers: We engage third party suppliers who may process your Personal Data on our behalf for the above Purposes. These include the following: