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Our Privacy Policy

This Privacy Policy ("the Policy") sets out the terms under which AlwaysEsim collects, uses, discloses, transfers, and retains your personal information, as well as your rights and choices regarding your personal information. It should be read in conjunction with our General Terms and Conditions and, if you use our Services, our Services Terms of Use.

When we use the terms "AlwaysEsim," "we," "our," or "us," we refer to AlwaysEsim, operated via Alwaysesim.com from Canada, which provides global eSIM connectivity services around the world.

If access to AlwaysEsim services has been granted to you by a third party (for example, a travel agency or your employer), AlwaysEsim may receive your personal information from them. You are also advised to review their own privacy policy, as these entities may collect, process, and manage your personal information differently than AlwaysEsim.

Personal Information We Collect and Methods of Collection

Personal information means any information about an identifiable individual. We detail the data we collect in the table below and explain how we use it.

We collect personal information in various ways, depending on your use of our Services and Platforms.

• Directly from you: When you provide it to us, notably when creating an AlwaysEsim account, registering to receive our communications, purchasing an eSIM, communicating with us via email, or uploading Content to any of our websites.
• Through your use of the Services or Platforms: We obtain data such as your IP address, cookie identifiers, your location, the device and browser you use, as well as how you navigate and interact on our website or other third-party websites. Some of this information is collected using cookies and similar technologies. For further details on this matter, please refer to our cookie policy.
• From third parties: When approved by you or permitted by law, or when necessary to provide you with the Services in certain situations. For example: when the Services have been sold or provided to you by a third party (such as an employer); when you have authorized a third-party website to share your personal contact details with us (for example, when you access your AlwaysEsim account via Facebook); when we conduct marketing collaborations with third parties; and from public sources or third-party-managed sources, such as data brokers (notably when we are required to perform eKYC checks to grant you access to the Services).

Information We Collect

As part of your use of our Services or Platform, or your interactions of any other nature with us, we collect, use, retain, and share the personal information listed below:

If You Are a User of Our Services or Platforms* (*as applicable)

Personal information necessary for setting up your account
First name, last name, email addresses, postal address or location (country, province/state, city), telephone numbers**.
**If access to the Services is granted to you by a third party, this may encompass data relating to your relationship with that third party (for example, an employment relationship).

Third-Party Login Information
If you choose to create an account through a third-party platform (for example, Apple, Google, or Facebook), we are likely to automatically receive login information from this third party. The data received varies depending on the information you shared with the third party as well as your preferences within the third-party platform (for example, you may have enabled Apple's "Hide My Email" feature). Please consult the privacy notice of the relevant third party for additional details.

Personal information required for compliance checks (including biometrics)
If applicable laws and regulations require it, such as in the event of mandatory eKYC verifications, AlwaysEsim may process data categories such as biometrics, date of birth, educational credentials, identity cards (or other identification numbers), geographic location, relevant information concerning business partners, as well as any other information related to export controls or customs compliance.

Personal information required for customer satisfaction
To the extent permitted by law or with your authorization, AlwaysEsim may aggregate information collected directly or indirectly to ensure the completeness and accuracy of such data, to enable AlwaysEsim to more appropriately personalize its interactions with you, and to determine which information best matches your interests or needs.

Data generated by your use or participation in AlwaysEsim web pages and applications

• Usage Data: AlwaysEsim processes certain usage-related data, such as information concerning your browser, your operating system, or the IP address from which you view the websites. AlwaysEsim also processes information relating to your use of its web services, notably pages viewed, consultation duration of a page, the referring page that led you to the websites, as well as hyperlinks selected on the websites.
• Device and Location Information: Generic data of your device such as your IP address, brand, model, and operating system; imprecise location based on your IP address; precise location data originating from your mobile device.
• Preference Information: Specific consents granted or denied, preferences relating to emails, push notifications, and cookies; preferred language, currency, and departure airport.
• Communication Information: The content of communications we send to you and receive from you, including comments, help requests, and inquiries; information pertaining to such communications, such as the time and date of dispatch as well as the nature of your interaction (for example, open rate and click-through rate).
• User Content: The content you upload to our websites or related thereto (such as comments, photographs, videos, recommendations, preferences, reviews) as well as data associated with such content, such as the time and date related thereto.
• Your participation with us on social media platforms (such as Instagram, X/Twitter, or Facebook) or on third-party review platforms, such as Trustpilot, including comments, photographs, videos, and publicly accessible information concerning your social media account. If we appreciate your content, we may contact you to verify if you consent to its republication, or we could use any review formulated regarding AlwaysEsim for advertising and promotional purposes.
• As part of your participation in a survey, we collect the information you transmit via this medium. If the survey is administered by a third-party service provider, that third party's privacy policy governs the collection, use, and disclosure of your information.

If You Are an Employee of a Partner or Prospective Partner of AlwaysEsim

Personal information pertaining to your business relationship with AlwaysEsim
Your employer's company name and industry sector, your title, role, department, and function, as well as the history of commercial relations between your company and AlwaysEsim.

Signature and Contact Details
If we need to send documents to you for signature, we retain your contact details, as well as your title and role within the company. We may ask you for and record additional information to validate that you possess the requisite authority to sign on behalf of your company.

If You Apply for a Position at AlwaysEsim

Personal information obtained as part of your recruitment process
First name, last name, email addresses, postal address or location (country, province/state, city), telephone numbers, as well as any other personal information you communicate to us via your resume, cover letter, or throughout the interview and selection procedure.

Special Categories of Personal Information

These are data categories of a more sensitive nature, such as information touching on your health, religious beliefs, or ethnic origin. We generally do not collect these categories of information, but you retain the option to disclose this type of data, for example when you communicate with our support team or if you provide comments on the accessibility of our Platform.

Purposes and Methods of Using Your Personal Information

We may use your personal information for the following purposes, or for a combination of these purposes:

• When we perform a contract concluded with you or a third party, such as your employer. This encompasses providing our services to you.
• When required for the conduct of our business or the pursuit of AlwaysEsim's legitimate interests. For example:
  • Improving our Services and Platform as well as developing product features, or correcting anomalies on our Platform.
  • Strengthening security and preventing fraud, including evaluating compliance with our acceptable use policy.
  • Responding to your inquiries and granting assistance, when you are eligible to receive support from AlwaysEsim.
  • Personalizing your experience, for example to tailor content and suggestions.
  • Conducting surveys and market research, routing advertising communications, or inviting you to review us on a third-party review platform, such as Trustpilot (when consent has been granted).
  • Executing various internal business operations, such as data analysis, accounting audits, fraud detection, designing new products or services, improving or modifying our Services or Platform, identifying usage trends and outlooks, evaluating the effectiveness of advertising campaigns, and managing our business.
• When necessary to exercise or respect our own legal rights and obligations, for example if the law obliges us to retain information or perform eKYC checks in certain countries.
• When we have collected your consent. In scenarios where you have expressly consented to the processing of your personal information, you are entirely free to withdraw this consent at any time, either by using the functionality made available to formulate and withdraw consent, or by contacting us at legal@alwaysesim.com. Nevertheless, please note that we may retain the right to continue processing your personal information if it is justified on one of the following bases:
  • The performance of our contract with you or your company.
  • The exercise and respect of our own legal rights and obligations.
  • The pursuit of our legitimate interests, including, without limitation, the operation of our Platform and business, as well as the provision of Services to you. When we process your personal information based on a legitimate interest, we do so only on the condition that the processing is relevant, adequate, and restricted to what is strictly required regarding the initial collection purpose.
  • The establishment, exercise, or defense of legal claims in case of need.
  • The fulfillment of a task carried out in the public interest.

Persons Authorized to Access Your Personal Information

• AlwaysEsim employees. Certain AlwaysEsim employees have access to your data to contribute to the smooth running of all operations set out in the "Purposes and Methods of Using Your Information" section of this privacy policy.
• AlwaysEsim group companies and employees. AlwaysEsim is an international enterprise, and our workforce is dispersed across the globe. Access is strictly restricted to individuals justifying a legitimate professional need.
• External service providers. AlwaysEsim relies on third parties to ensure the provision of certain components of our Services or to support the technical infrastructure of our Platform, which includes our network connectivity providers, hosting service providers, payment processing, etc. We exclusively use service providers that provide adequate contractual guarantees regarding the transfer and processing of the information they handle.
• Independent third-party services, websites, and businesses. This may occur as part of a promotion, advertising event, or webinar. AlwaysEsim also uses a third-party review platform, Trustpilot, which may contact you to collect your feedback on your experiences with AlwaysEsim.
• Distribution partners. AlwaysEsim uses distribution partners to market its Services, and we may be led to communicate information to them, particularly if you acquired services from them rather than directly from AlwaysEsim.
• Other disclosures. Including:
  • to comply with laws or respond to judicial procedures (notably subpoenas and court orders) as well as requests emanating from governmental or public authorities;
  • to collaborate with regulatory bodies;
  • to allow third parties to conduct investigations, prevent, or initiate actions against actual or suspected prohibited activities, including fraud or misuse of our Services or Platform;
  • toward third parties to whom we might choose to assign or merge portions of our business or assets, or from whom we might seek to acquire other businesses or assets. If such a transformation occurs, the new owners of the business will be authorized to use your personal information according to the terms established in this privacy policy.

Retention Period of Your Personal Information

We retain your personal information only for the period required for the purposes motivating its collection, or as long as the law obliges us to keep it. This duration varies depending on the reason for which the data was collected and the existence of a continuous legal foundation (such as our legitimate interests, or the performance of our contract with you). As soon as we no longer have any motive to retain your data, we proceed to delete or anonymize it so that it no longer allows you to be identified. You have the faculty to delete your personal information or request us to proceed with this deletion at any time. Details concerning the procedure to follow appear in the "Know Your Rights" section below. Please note that, under certain circumstances, AlwaysEsim may be imposed by law the obligation to retain and process all or part of your personal information, or to justify compelling legitimate interests to maintain its retention, even consecutively to a deletion request. By way of example, AlwaysEsim is required to retain certain personal information to satisfy its legal know-your-customer (eKYC) obligations.

Measures Ensuring the Security of Your Personal Information

We have instituted adequate security measures aiming to prevent the loss, use, unauthorized access, alteration, or disclosure of your personal information. Furthermore, we restrict access to your personal information to the sole employees, contractors, and other third parties who require knowledge thereof in the framework of their professional duties. These individuals will process your data only on the basis of our directives and remain subject to a strict obligation of confidentiality. Nevertheless, no method of transmission over the Internet, by mobile technology, or electronic storage method proves entirely secure. Consequently, despite our efforts to maintain appropriate safeguards, we are not in a position to guarantee the absolute security of your personal information.

International Transfer of Your Personal Information

Please note that your data will be subject to storage and processing on a global scale. More precisely, your personal information will be securely stored within data centers distributed across the world, and not necessarily in your country of residence. The exact location of these data centers depends on where you are located at the time of using the Platform or Services, as well as the location of third parties with whom we share personal information (see the section "Persons Authorized to Access Your Personal Information"). The laws and regulations in force in the countries where processing takes place are likely not to offer the same level of protection of personal information as the rules applicable in your own country. Nevertheless, we put in place safeguards to ensure the protection of your data during their transfer. Please consult the "Compliance with Local Regulations" section below to obtain further information.

Know Your Rights

If we hold personal information concerning you, you possess determined prerogatives (depending on your location). These encompass:

• The right to request access to your personal information. This faculty allows you to receive a copy of the personal information we may hold about you and to verify that we process it lawfully.
• The right to request rectification of personal information we hold about you in the presence of inaccuracies (which we are entitled to ask you to validate).
• The right to request erasure of your personal information when there is no longer a legitimate motive justifying the continuation of its retention. We may not always be able to comply with this request if a specific legal obligation remains prohibiting its elimination.
• The right to request a restriction of the processing of your personal information, meaning to require that we limit the processing of your personal information to determined purposes.
• The right to object to the processing of your personal information when we invoke a legitimate interest to proceed. In certain situations, we can demonstrate that we indeed possess a compelling legitimate interest.
• You hold the absolute right to object at any time to the processing of your personal information for direct marketing purposes.
• The right to withdraw your consent at any time, when we base the processing of your personal information on your consent.
• The right to request the transfer of your personal information to a third party.

If you wish to exercise any of these prerogatives, our websites and applications integrate functionalities allowing you to execute most of the actions enumerated above. If you wish to exercise a right that is not accessible via these functionalities, please contact us by resorting to the contact details indicated in the "Contact Information" section.

Children

Our Services and Platforms are not directed to children under the age of 13 and we do not knowingly collect personal information from individuals under the age of 13. If you note that an individual under the age of 13 has transmitted their personal information to us, please notify us at legal@alwaysesim.com.

Contact Information

If you have queries regarding how we process your personal information or if you wish to exercise your rights under this privacy policy, please contact legal@alwaysesim.com.

If you need access to this privacy policy in an alternative format due to a disability, please communicate with our support team via the functionalities integrated into the application or by using the email address support@alwaysesim.com.

If you are not satisfied with our response, and you are located within the European Union or the United Kingdom, you potentially possess the right to lodge a complaint with your local data protection supervisory authority.

Compliance with Local Regulations

Canada (PIPEDA and Quebec Law 25)

To the extent AlwaysEsim is subject to the federal Personal Information Protection and Electronic Documents Act (PIPEDA) as well as provincial laws such as the Act Respecting the Protection of Personal Information in the Private Sector (including Quebec Law 25), the following provisions apply:

• AlwaysEsim has designated a person charged with the protection of personal information (Privacy Officer). You can communicate with our legal compliance and privacy team at legal@alwaysesim.com for any question, access request, rectification, or complaint concerning your personal information.
• In the event of a confidentiality incident affecting personal information that presents a risk of serious harm, AlwaysEsim will take reasonable steps to notify competent supervisory authorities (such as the Commission d'accès à l'information du Québec) as well as the individuals concerned, in accordance with applicable Canadian law requirements.
• Any transfer of personal information outside Canada or Quebec is subject to a prior assessment aiming to guarantee that the data benefits from a level of protection equivalent to that provided by Canadian laws.

EU/EEA or Country with National Legislation Comparable to GDPR

Who assumes the function of Data Protection Officer for the data controller? You can reach AlwaysEsim's Data Protection Officer at any time at legal@alwaysesim.com.

What is the competent supervisory authority? The contact details of your designated data protection supervisor can be consulted on the website of the European Data Protection Board.

How does AlwaysEsim justify international data transfers? As an international player, AlwaysEsim also holds affiliated companies and third-party service providers in countries located outside the European Economic Area (the "EEA"). AlwaysEsim is likely to transfer your personal information to countries located outside the EEA in the framework of its international commercial activities. If AlwaysEsim transfers personal information from an EU or EEA member country to a country located outside the EEA for which the European Commission has not granted an adequacy decision, AlwaysEsim makes use of EU standard contractual clauses to require by contract that the data importer apply to your personal information a level of protection equivalent to that in force within the EEA. You can also obtain additional details and review their positions on international data protection questions on the European Commission's webpage dedicated to the international dimension of data protection.

Colombia

If AlwaysEsim is subject to the provisions of Colombian Law 1581 of 2012 and Decree 1377 of 2013, the following stipulations apply:
In Colombia, you possess the right to:

• consult, update, and correct your personal information;
• demand proof of your consent;
• obtain upon request information as to how AlwaysEsim processes your personal information;
• lodge a complaint with the Superintendence of Industry and Commerce ("SIC") in case of breach of applicable laws;
• withdraw your consent and/or request the erasure of your personal information, subject to the non-existence of an additional legal or contractual obligation constraining AlwaysEsim to retain your personal information in its databases.

Kingdom of Saudi Arabia (KSA)

To the extent the provisions of the Personal Data Protection Law ("PDPL") apply to AlwaysEsim, the following finds application:

• AlwaysEsim processes your personal information by electronic means for the purposes of collection, storage, and other processing operations set out above.
• AlwaysEsim will destroy your personal information by electronic means when required for the purposes described above.
• Your personal information will be retained and backed up by AlwaysEsim in a country other than Saudi Arabia, for our general business purposes, such as outsourcing and data processing.
• Depending on the targeted objective, personal information may be subject to sharing on a regular or occasional basis.
• Compensation can only be sought if the courts have established that you have suffered material or moral harm as a result of a breach covered by the PDPL and its implementing regulations.
• If AlwaysEsim contravenes the PDPL, you have the faculty to file a complaint with our support team. If the manner in which we process your complaint does not give you satisfaction, you can lodge a complaint with the competent authority: the Saudi Data and Artificial Intelligence Authority (SDAIA), Digital City, Riyadh, 12382, Kingdom of Saudi Arabia, website: sdaia.gov.sa

Malaysia

To the extent AlwaysEsim is subject to the provisions of the Malaysian Personal Data Protection Act ("PDPA"), the following text applies:
AlwaysEsim has implemented technologies, security devices, and rigorous policies aiming to protect the confidentiality of users' personal information, including a version in the Malay language (Bahasa Malaysia) of this privacy declaration.

Philippines

In the Philippines, you are entitled to:

• file an action for indemnity as ordered in final resort by the National Privacy Commission or a competent court if you have suffered harm stemming from inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal information, violating your rights and freedoms as a data subject;
• lodge a complaint with the National Privacy Commission if your privacy has been violated, if your personal information has been compromised, or if you have personally suffered the repercussions of a breach of the Data Privacy Act;
• benefit from your data portability rights. Your successors-in-interest and legal heirs may assert your rights at any time following your death or when you find yourself in incapacity or incompetence to exercise them yourself.

South Africa

To the extent AlwaysEsim is subject to the provisions of the South African Protection of Personal Information Act of 2013 ("POPIA"), the following provisions apply:

• The expressions "Personal Data" or "Personal Information" within this Privacy Declaration designate personal information as defined in POPIA. The terms "You" and "Your" in this Privacy Declaration refer to a natural person or a legal entity as defined in POPIA.
• You may request clarifications regarding the personal information we hold about you under the Promotion of Access to Information Act of 2000 ("PAIA").
• If you, as a natural person or legal entity, consider that AlwaysEsim, as a responsible party, has employed your personal information in contravention of POPIA, you must in the first place attempt to settle the dispute with AlwaysEsim. If this process does not bring you satisfaction, you possess the right to file a complaint with the Information Regulator, which can be reached at the following contact details:
  JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001, PO Box 31533, Braamfontein, Johannesburg, 2017
  Email: complaints.IR@justice.gov.za
  Inquiries: inforeg@justice.gov.za

United States

To the extent AlwaysEsim is subject to the provisions of the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), hereinafter designated the "CCPA," or the laws of other American states endowed with comparable provisions, the following rules apply:
You possess the right to:

• know what personal information the business has collected about the consumer, including categories of personal information, categories of sources from which personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, categories of third parties to whom the business discloses personal information, as well as the specific pieces of personal information the business has collected concerning the consumer;
• request the deletion of personal information the company has collected from the consumer (subject to certain exceptions);
• rectify erroneous personal information a business holds regarding a consumer;
• opt out of consenting to the business selling or sharing your personal information (where applicable);
• impose restrictions on the use or disclosure by the business of sensitive personal information (subject to certain exceptions, where applicable);
• benefit from equal treatment in the exercise of these rights.

California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined by California legislation): biometric data, geolocation, social security number or other government-issued identification information, account login identifier, payment data. This information is collected for transaction processing, legal compliance, business management, or service provision purposes. Please note that we do not use this information for purposes not mentioned in Section 1798.121 of the California Privacy Rights Act.