1. Introduction

This Privacy Policy ("Policy") describes how we collects, uses, discloses, and protects your personal data when you use our eSIM Number services and related services (collectively, the "Service").

Our company, AtlasV Global Pte. Ltd. ("Company," "we," "us," or "our"), is the data controller responsible for your personal data.

This Policy should be read in conjunction with our Terms and Conditions. By using our Service, you agree to the collection and use of information in accordance with this Policy.

2. What Personal Data We Collect and How

We collect personal data to provide and improve our Service. The types of data we collect depend on how you interact with us.

2.1. Information You Provide Directly

• Account Information: When you create an account, we collect your first and last name, email address, country of residence, and contact phone number.
• Identity Verification (eKYC) Information: In certain jurisdictions where required by law to provide a phone number, we may need to verify your identity. This may involve collecting your date of birth, a copy of your government-issued ID (such as a passport or driver's license), and in some cases, biometric information (like a selfie for comparison).
• Payment Information: When you make a purchase, your payment details are processed by our third-party payment providers. We do not store your full credit card number but may receive transaction identifiers and summary information.
• Communications with Us: We collect the content of your communications when you contact our customer support, provide feedback, or participate in surveys.

2.2. Information Collected Automatically When You Use the Service

• Device and Connection Information: We collect your IP address, device type (make and model), operating system, browser type, and unique device identifiers.
• Usage Data: We collect information about your interaction with our Platform (website and app), such as pages visited, features used, time and date of access, and clickstream data.
• Location Information: We may collect your generic location from your IP address. With your consent, we may collect more specific location data from your mobile device to improve service quality.
• Telecommunications and Traffic Data: As we provide an "eSIM Number," we process data required for transmitting communications. This includes:
  • Call Detail Records (CDRs/xDRs): such as the calling and receiving numbers (MSISDN), duration of the call, and time/date.
  • SMS/MMS Logs: such as sending and receiving numbers and time/date.
  • Data Usage: The volume of data consumed.
  • Note: We do not typically store the content of your calls or SMS messages, unless it is a necessary part of a service like voicemail, or where we are required to do so by law.

2.3. Information from Third Parties

• Third-Party Log-in: If you create an account using a third-party service (like Apple, Google, or Facebook), we receive information from that service, such as your name and email address, as permitted by your privacy settings on that service.
• Third-Party Partners: We may receive information about you from our distribution partners (e.g., travel agencies) if you purchased our Service through them.

3. How and Why We Use Your Personal Data

We use your personal data based on the following legal grounds:

• To Perform Our Contract with You:

  • To set up and maintain your account.
  • To provide, operate, and manage the Service you have purchased.
  • To process your payments and transactions.
  • To provide you with customer support.

• For Our Legitimate Interests:

  • To improve and personalize our Service and develop new features.
  • To ensure the security of our Platform, prevent fraud, and enforce our Acceptable Use Policy.
  • To conduct data analysis and market research to understand user trends.
  • To send you non-promotional communications about your account or our Service.

• To Comply with a Legal Obligation:

  • To perform eKYC checks and verify your identity as required by telecommunications regulations in certain countries.
  • To respond to lawful requests from government authorities, courts, and law enforcement.
  • To retain records for tax and financial purposes.

• With Your Consent:

  • To send you marketing communications about our services and promotions.
  • To collect precise location data from your device.
  • To place non-essential cookies and similar technologies on your device. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

4. Who We Share Your Personal Data With

We do not sell your personal data. We may share your information with the following categories of third parties:

• Network Operators and Telecommunications Partners: We share data with local mobile network operators around the world to enable your eSIM connectivity and number services.
• Service Providers: We engage third parties to perform functions on our behalf, including payment processors, cloud hosting providers, identity verification services, customer support software providers, and data analytics tools.
• Legal and Regulatory Authorities: We may disclose your data to law enforcement, government bodies, or courts where we are legally required to do so or to protect our legal rights.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the new owner.

5. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure.

6. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Policy, or as required to comply with our legal obligations (for example, eKYC records or financial transaction data), resolve disputes, and enforce our agreements. When we no longer have a legitimate need to process your data, we will either delete or anonymize it.

7. International Data Transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We ensure that appropriate safeguards are in place for such transfers, such as by using the European Commission's Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms.

8. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right to Access: To request a copy of the personal data we hold about you.
• Right to Rectification: To request that we correct any inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): To request that we delete your personal data, subject to certain exceptions.
• Right to Restrict Processing: To request that we limit the processing of your personal data in certain circumstances.
• Right to Data Portability: To receive your data in a structured, machine-readable format and have it transferred to another controller.
• Right to Object: To object to the processing of your personal data where we are relying on a legitimate interest.
• Right to Withdraw Consent: To withdraw your consent at any time for processing based on consent.

To exercise any of these rights, please contact us using the details below. You may also be able to manage some of your data directly through your account settings.

9. Children's Privacy

Our Service is not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under this age, we will take steps to delete such information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and, where appropriate, by other means. We encourage you to review this Policy periodically.

11. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at:

• Email: support@esimnum.com