Privacy Policy

Version 1.1 updated 11.10.23

Introduction

This Privacy Policy explains what personal and other information is collected by us, easySim, as part of our activities, and how we use that information.

easySim recognises that your privacy is important to you and that it is your right to control your personal information. We recommend that you read this Privacy Policy in full to ensure that you understand what information we collect, what we do with that information, who we share it with, and how long we keep it. To make this easier we have divided it up into the following sections:

1. Explanation of certain words and expressions used in this Privacy Policy
2. What personal information do we collect about you?
3. What do we do with your personal information?
4. Who do we share your personal information with?
5. How do we keep your personal information secure?
6. For how long do we keep your personal information?
7. What are your data protection rights?
8. How can you contact us?

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments, so please review it frequently. If we update our Privacy Policy and the amendments involve a material change to the way we collect, use, share, store or otherwise process your personal information then we will take appropriate steps to inform you, consistent with the significance of the changes we make.

Section 1 Explanation of certain words and expressions used in this Privacy Policy

In this Privacy Policy, the following words have the following meanings:

“Data Protection Laws” means (i) the Data Protection Act 2018 (ii) the UK GDPR (as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019) (iii) the Electronic Communications (EC Directive) Regulations 2003, and (iv) any other data protection laws and regulations, orders and any codes of practice, guidelines and recommendations issued by the Information Commissioner’s Office or any replacement or equivalent body, as amended and in force from time to time.

“easySim” means easySim Ltd, a company registered in England and Wales with number 14894554 and its registered office at Unit 1.1 Central Point, Kirpal Road, Portsmouth PO3 6FH, Hampshire, United Kingdom.

“easySim Mobile App” means an iOS or Android easySim’s proprietary mobile application which enables a customer to set up an Account, use the Services, and benefit from such additional features and functionality that we may from time to time make available.

“easySim Webapp” means easySim’s proprietary web application that may be accessed by a customer at https://www.easysim.global, and which enables the customer to set up an account, use the Services, and benefit from such additional features and functionality that we may from time to time make available.

“personal information” means information relating to an identified or identifiable individual, including all information that is considered to be “personal data” under Data Protection Laws.

“Services” means the provision of data plans enabling customers to connect their phones or other devices to the internet.

Section 2 What personal information do we collect about you?

Depending on whether you interact with us as a customer, supplier, employee, job candidate or visitor to our website, the types of personal information that we collect include the following:

• If you are a customer of our Services, your name, email address, mobile phone number, country of residence, IP address, and debit or credit card (or other payment method) details.
• If you are one of our suppliers, your name, email address, phone numbers, postal address, bank account details, and VAT registration details.
• If you are one of our employees, your name, email address, phone numbers, postal address, qualifications, references, tax and national insurance details, bank account details, emergency contacts, medical conditions, and remuneration details.
• If you are a job candidate, your name, email address, phone numbers, postal address, qualifications and references.
• If you are a visitor to our website, your IP address – please see our Cookie Policy for more detail.

Section 3 What do we do with your personal information?

We collect and use your personal information:

• If you are a customer of our Services, your name, email address, mobile phone number, country of residence, IP address, and debit or credit card (or other payment method) details.
• To provide you with the Services that you have purchased.
• To perform our obligations under a contract with you.
• To manage your account, process orders, provide you with information and respond to your enquiries.
• To manage risk and prevent illegal or prohibited activities, and to keep things secure and safe.
• To resolve issues or fix problems on the easySim Webapp or the easySim Mobile Apps, and to improve our Services.
• If you’ve agreed to receive it, to send you marketing about products and services that we think may be of interest to you.
• For legal, regulatory or business reasons such as assisting with crime and fraud prevention.

The legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it, but we will only do where one of the following applies:

• We have your consent.
• We need the personal information to perform a contract with you.
• Where the processing of your personal information is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

Section 4 Who do we share your personal information with?

We may disclose your personal information to third parties in the following circumstances:

• If you are a customer of our Services, your name, email address, country of residence, IP address, and debit or credit card (or other payment method) details.
• To services providers who provide services to us (for example, to support the delivery of, provide functionality for, or help to enhance the security of the Services), or process personal information for content customisation, personalisation, ad selection and ad delivery and reporting, measurement purposes, or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information. Our third party services providers include:
o Google Cloud Platform
o Zoho
o Mailchimp
o Microsoft 365
o Sendgrid
o Klaviyo

• To competent law enforcement or regulatory bodies, HMRC, other government agencies, courts or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person.
• To enforce or defend our legal rights, or to protect the rights, property, or safety of easySim, our customers, or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.
• If you’ve agreed to receive it, to third parties which show you products and services that they think may be of interest to you.
• To other persons where you have given us your permission.

The legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it, but we will only do where one of the following applies:

• We have your consent.
• We need the personal information to perform a contract with you.
• Where the processing of your personal information is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

Where your personal information is transferred to companies outside the UK, we make sure that it is protected in a similar way to how we protect your information within the UK and in compliance with Data Protections Laws. We do this in a number of ways. For example, we may use specific contracts which give personal information the same protection it has in the UK. Or we ensure that the country to which the personal data is transferred has been deemed by the UK government to provide an adequate level of protection.

Section 5 How we you keep your personal information secure?

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of the easySim Webapp or an easySim Mobile App, taking into account the likelihood and severity those risks might pose to your rights and freedoms. Those measures include, but are not limited to, using encryption, passwords, firewalls, anti-virus/malware software, cloud storage with two factor authentication (2FA), and maintaining regular backups.

Please be aware that, while we make the security of the Services and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept that this is the case and provide your information at your own risk.

Section 6 For how long do we keep your personal information?

We keep your personal information for the following periods of time:

• If you are a customer of our Services, for up to 1 year after the end of our relationship.
• If you are one of our suppliers, for up to 6 years after the end of our relationship.
• If you are one of our employees, for up to 6 years after the end of your employment.
• If you are an unsuccessful job candidate, for up to 6 months after the end of the recruitment campaign.
• If you have agreed to receive marketing, for up to 1 year after the end of the marketing campaign.

In all cases we will only keep your personal information for as long as we need it.

Section 7 What are your data protection rights?

You have the following data protection rights:

1. You have the right at any time to withdraw your consent to our processing of your personal information.
2. You have the right to be told what personal information we hold about you on our database and how we process that data.
3. You have the right to request that we provide you with a copy (in a commonly used electronic format) of all the personal information that we hold about you. Unless you make repeated requests, we will not charge a fee for providing you with a copy of this data.
4. You have the right to request that we correct any inaccurate or incomplete personal information that we hold about you.
5. You have the right to request that we irretrievably delete all personal information that we hold about you (the so-called “right to be forgotten”). Note that there are limited circumstances in which we are legally entitled to refuse to comply with this request.
6. You have the right to request that we transmit all the personal information that we hold about you (in a structured, commonly used and machine-readable form) to another organisation’s IT environment. Note that we are only legally obliged to comply with this request if it is technically feasible for us to do so.
7. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or by replying to any marketing text messages with the word “STOP”.
8. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the UK Information Commissioner’s Office at: https://ico.org.uk/concerns/.

If you wish to exercise any of the rights set out in 1 – 7 above you can do so at any time by contacting our customer services here. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with Data Protection Laws.

Section 8 How can you contact us?

If you have any questions about this Privacy Policy, our practices, or your dealings with easySim, you can contact our customer services here.