PRIVACY POLICY

IxoSim Mobile LLC ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website ixosim.com (the "Site") or purchase and use our eSIM services (collectively, the "Services").

Please read this Privacy Policy carefully. BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION AND USE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICES.

This Privacy Policy is incorporated into and forms part of our Terms and Conditions.

1. WHO WE ARE

IxoSim Mobile LLC is a provider of global eSIM connectivity solutions. We act as the "Data Controller" of your personal information for the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), UK data protection laws, and other relevant international frameworks [citation:1][citation:3].

Our registered office address:
IxoSim Mobile LLC
14171 Denise Dr
Westminster, CA 92683
United States

2. INFORMATION WE COLLECT

We collect only the minimum information necessary to provide you with our eSIM Services. We adhere to the principle of data minimization [citation:3][citation:7].

2.1 Information You Provide Directly

• Account Information: When you register for an account, we collect your name, email address, and phone number [citation:9].
• Payment Information: When you purchase a plan, we collect payment method details. Note: All payment processing is handled by our secure third-party payment processors. We do not store full credit card numbers on our servers.
• Communications: When you contact our customer support, we collect the information you provide during those interactions.

2.2 Information Collected Automatically

• Technical Information: Your IP address, device type (name, model), operating system, browser type, and network information [citation:1].
• Usage Information: How you interact with our Site and Services, including pages visited, time and date of access, and features used.
• Device Identifiers: For eSIM service provision, we process technical identifiers such as IMSI (International Mobile Subscriber Identity) and IP addresses, which are standard for all mobile services worldwide and are used solely for technical connection purposes [citation:3].

2.3 Information from Third Parties

• Fraud Prevention Agencies: We may receive information from fraud prevention agencies (such as CIFAS-type organizations) to verify your identity and prevent fraudulent transactions [citation:1].
• Analytics Providers: We use analytics software (e.g., Google Analytics) to understand user behavior and improve our Services [citation:1].

3. HOW WE USE YOUR INFORMATION

We use your personal information only for the following legitimate purposes:

Purpose	Legal Basis
To create and manage your account	Performance of contract
To process payments and complete transactions	Performance of contract
To provide eSIM connectivity services	Performance of contract
To communicate with you about your account and service updates	Legitimate interests / Performance of contract
To detect, prevent, and address fraud or security incidents	Legitimate interests / Legal obligation
To analyze trends and improve our Services	Legitimate interests
To send marketing communications (only with your explicit consent)	Consent
To comply with legal obligations	Legal obligation

Note on marketing: We will only send you marketing emails if you have given us your explicit consent. You can withdraw this consent at any time by accessing your account settings or clicking the "unsubscribe" link in any marketing email [citation:1].

4. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our Site. Cookies are small text files placed on your device.

Types of cookies we use:

• Essential Cookies: Necessary for the Site to function (e.g., authentication, security). These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our Site (e.g., Google Analytics).
• Functionality Cookies: Remember your preferences to provide enhanced, personalized features.

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Site.

5. HOW WE SHARE YOUR INFORMATION

WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES. We only share your information in the following limited circumstances [citation:9]:

5.1 Network Partners (Telecom Operators)

To provide you with eSIM connectivity, we must share limited technical information (IMSI, MSISDN, IP address) with our network carrier partners. These partners are contractually bound to strict confidentiality and data protection obligations. They cannot see your name, email, payment details, or browsing activity [citation:3]. All communications are encrypted in transit (HTTPS, SFTP, SSH).

5.2 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment processing
• Cloud hosting and data storage
• Customer support tools
• Analytics services (e.g., Google Analytics)
• Email communication services

These providers are contractually obligated to protect your information and may only use it to provide services to us [citation:1].

5.3 Fraud Prevention Agencies

We may share information with fraud prevention agencies to verify identity and prevent fraudulent transactions. These agencies may retain records of our exchanges [citation:1].

5.4 Legal Compliance and Protection

We may disclose your information if required by law, regulation, legal process, or governmental request. We may also disclose information to:

• Enforce our Terms and Conditions
• Protect our rights, privacy, safety, or property
• Protect the public against harm
• Investigate or prevent fraud or illegal activities

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as a business asset. We will notify you of any such change [citation:1].

6. INTERNATIONAL DATA TRANSFERS

As a global eSIM provider, your information may be transferred to, stored, and processed in countries outside your country of residence, including the United States, the United Kingdom, and the European Economic Area (EEA) [citation:1].

When we transfer your data internationally, we implement appropriate safeguards to ensure your information remains protected in accordance with this Privacy Policy and applicable data protection laws, including:

• Standard Contractual Clauses approved by the European Commission
• UK International Data Transfer Agreements
• Verifying that recipients are located in countries with adequate data protection laws

Our primary data storage is on secure servers located in the [United States / United Kingdom / EEA] [citation:1].

7. DATA SECURITY

We take the security of your personal information seriously. We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction [citation:6][citation:9].

Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL protocols [citation:3][citation:6].
• Secure Storage: Your information is stored in secure databases with robust access controls and encryption at rest [citation:9].
• Access Controls: Strict internal access controls ensure only authorized personnel with a legitimate business need can access your data.
• Regular Testing: We conduct regular security assessments and penetration testing to identify and address vulnerabilities [citation:6].
• Incident Response: We have a comprehensive security incident response plan to quickly address any potential data breaches [citation:6].

While we implement strong safeguards, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to maintain the highest standards of protection.

8. DATA RETENTION

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to provide you with Services, comply with legal obligations, resolve disputes, and enforce our agreements [citation:3].

Specific retention periods:

• Account information: Retained for as long as your account is active, plus a reasonable period afterward to allow for account reactivation.
• Usage and communications data: Typically retained for up to 12 months for legitimate business purposes [citation:1].
• Payment information: Retained only as long as necessary to complete transactions and comply with tax and financial reporting requirements.
• Inactive accounts: Accounts inactive for 6 months may be deactivated and data deleted in accordance with this policy.

After the retention period expires, your personal information will be securely deleted or anonymized so that it can no longer be associated with you [citation:3].

9. YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information. We respect and uphold these rights [citation:1][citation:2].

9.1 Your Rights Include:

• Right of Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal information in certain circumstances.
• Right to Restriction: Request that we restrict processing of your information.
• Right to Data Portability: Request transfer of your information to another organization in a structured, commonly used, machine-readable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time where we rely on consent for processing [citation:1].
• Right to Complain: Lodge a complaint with a supervisory authority.

9.2 How to Exercise Your Rights

To exercise any of these rights, please contact us using the details in Section 13. We will respond to your request within one month (or up to two additional months for complex requests) [citation:2].

We may need to verify your identity before processing your request. This is a security measure to ensure that personal information is not disclosed to unauthorized persons.

Note: Some rights may not apply in all circumstances. If we cannot comply with your request, we will explain why.

10. CHILDREN'S PRIVACY

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately [citation:1].

If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information promptly.

11. THIRD-PARTY WEBSITES AND SERVICES

Our Site may contain links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices [citation:2].

We encourage you to read the privacy policy of every website you visit.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational reasons [citation:1]. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification to the address associated with your account (for significant changes)
• Displaying a prominent notice on our Site

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our Services after any changes constitutes your acceptance of the revised policy.

13. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: privacy@ixosim.com
• Data Protection Officer: dpo@ixosim.com
• Postal Address:
  IxoSim Mobile LLC
  Attn: Privacy Officer
  Contact Form: Available on our website at ixosim.com/contact

13.1 Supervisory Authority

You have the right to lodge a complaint with the data protection authority in your country of residence. For users in the European Economic Area, you may contact your local Data Protection Authority. For users in the United Kingdom, you may contact the Information Commissioner's Office (ICO) at https://ico.org.uk/concerns [citation:1].

14. SPECIFIC JURISDICTION PROVISIONS

14.1 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete personal information, and the right to opt-out of the sale or sharing of personal information. IxoSim Mobile LLC does not sell your personal information. To exercise your California privacy rights, please contact us at privacy@ixosim.com.

14.2 UK and EEA Residents (GDPR)

If you are located in the UK or European Economic Area, you have the rights described in Section 9 under the General Data Protection Regulation. Our legal bases for processing are set forth in Section 3.

14.3 Other Jurisdictions

If you are located in other jurisdictions with specific data protection laws, we comply with applicable local requirements.