Privacy Policy

This privacy policy explains how ESimTel Limited collects, uses, and protects your personal information when you use our services or visit our website. It outlines the types of data we collect, the reasons we collect it, who we share it with, and your rights regarding your data under the GDPR.

1. Introduction

This privacy policy (“Notice”) is intended to inform you about how your Personal Data will be handled by ESimTel Limited (“ESimTel,” “we,” “us,” or “our”). It details the information, including personal information, that we collect from you or that you provide to us (“Personal Data”) when you contact us through our channels, such as our application or website, or when you contract for our services. We are providing this information, including details about your data protection rights, as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

2. ESimTel as Data Controller

For the purposes of this Notice, the controller of your personal data is ESimTel Limited . ESimTel is responsible for your Personal Data.

We are committed to respecting your fundamental right to the protection of your Personal Data, and this Notice is designed to inform you about our processing of your data.

3. Types of Personal Data We Process About You

Category of Personal Data	Details
Website Usage and Device Data: When you visit our application or website.	Your visits and interactions with our website, including the webpages you visit, time and date of access, what you click on, and 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 you access. Most of this Personal Data is collected using cookies. Please see our Cookies Policy for more information.
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 license, or similar documentation for identification (where necessary); and other details you provide when interacting with us regarding the purchase of an e-SIM.

4. Sources of Your Personal Data

We collect Personal Data during our relationship with you or when you visit our website or application. We will collect this data either: (1) directly from you, or (2) indirectly from third parties (for example, through our affiliates or travel agencies once you have contracted for our services).

When you browse our website, different cookies and other tracking devices may be installed on your device, as outlined in our Cookies Policy. Where we use cookies that are not essential for the website to operate, we will request your consent.

5. For What Purpose and on What Legal Basis Do We Process Personal Data?

The table below outlines the key legal basis, nature of processing, and purposes for which we obtain and process your Personal Data.

Legal Basis	Nature of Processing and Purposes	Categories of Personal Data
Compliance with a Legal Obligation	ESimTel may process your Personal Data when it is necessary to comply with legal obligations under European Union and/or applicable laws, including safeguarding and complying with law enforcement requests.	Customer Data, Website Data
Performance of a Contract	To provide you with access to and allow you to use our website. To manage the purchase of the e-SIM or data plan you buy from us, including payment. To calculate and issue charges for services provided to you. To review and address customer issues, queries, complaints, or requests. To manage and perform any after-sales services. To manage your user registration and allow access to ESimTel’s private user area.	Customer Data, Website Data
Legitimate Interest	To facilitate the use of your e-SIM or data plan, including account administration and customer care. To better understand how customers use our website to improve it. To tailor products and services and, if you consent, direct marketing. To monitor and prevent cybersecurity issues and unauthorized use of our IT systems. To streamline our business processes using external platforms. To conduct internal business reviews and, if necessary, contact the customer if fraud, identity theft, or illegal activity is detected. To record calls for training and to improve our customer service. To conduct periodic reviews and satisfaction surveys to evaluate and improve service quality. To carry out other necessary business activities, including system testing, network monitoring, staff training, and quality control.	Customer Data, Website Data

6. With Whom Do We Share Personal Data?

Depending on the purpose, we may share your Personal Data with some or all of the following recipients:

ESimTel internal/intra-group entities: Internal departments and services (such as sales, marketing, or IT).
Telecommunications service providers: Service providers located in the jurisdiction for which the e-SIM service was purchased.
Regulatory authorities and law enforcement agencies: Where we are legally obligated to disclose your Personal Data, such as to the Revenue Commissioners, the Data Protection Commission, An Garda Síochána, or other applicable authorities.
Third-party advisors/professionals: Professional advisors who provide services to us, such as consultants or legal advisors.

7. International Data Transfers

If you are a user in the European Union, please note that your Personal Data will be transferred to certain recipients (primarily our external service providers) located outside the European Economic Area (“EEA”) in countries that may not have equivalent data protection laws (e.g., Thailand, Colombia). When such transfers occur, we ensure appropriate safeguards are in place by making sure that: a) transfers do not happen without our prior written authority, and b) an appropriate transfer mechanism, such as Module 2 of the Standard Contractual Clauses (as approved by the European Commission) or an adequacy decision, is used to protect your Personal Data. If you would like more information about these transfers, please contact us by emailing dpo@esimtel.diploy.in.

8. Your Data Protection Rights

Right	Further Information
Right of Access	You have the right to request a copy of the Personal Data we hold about you.
Right to Object	You have the right to object at any time to the processing of your Personal Data where ESimTel processes your data based on its legitimate interests.
Right to Rectification	You have the right to have any inaccurate Personal Data we hold about you updated or corrected.
Right to Erasure	In certain circumstances, you may have your Personal Data deleted. For example, if you exercise your right to object and we have no overriding reason to process your data, or if we no longer need your data for the purposes outlined in this Notice.
Right to Restriction of Processing	You have the right to ask us to restrict the processing of your Personal Data in certain cases, such as if you believe the data we hold is inaccurate or our use of it is unlawful.
Right to Data Portability	You may request that we provide you with your Personal Data in a structured, commonly used, and machine-readable format.
Right to Lodge a Complaint	You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or where an alleged infringement occurred. The relevant supervisory authority in Ireland is the Data Protection Commission. For more information, visit www.dataprotection.ie.
Right to Object to Automated Decision-Making, including Profiling	You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects concerning you. We may not be able to comply with this request where the processing is necessary to enter into or perform our contract with you or when authorized by law.

9. How Long Do We Retain Your Personal Data?

In general, we will store your Personal Data in accordance with applicable Irish and European Union laws and for as long as we have a relationship with you, plus a reasonable period afterward. Your data will be stored as long as necessary for the purpose(s) for which it was obtained. The criteria used to determine retention periods include:

The length of the contractual relationship plus 7.5 years from the date of termination.
Whether retention is necessary in light of ESimTel’s legal position (e.g., with respect to statutes of limitations, litigation, or regulatory investigations).
Whether there is a legal obligation to which ESimTel is subject.
6 months for connection history and call recordings.

10. Children’s Personal Data

ESimTel understands the importance of safeguarding the Personal Data of children, which we consider to be individuals under the age of 18 in Ireland or the equivalent age in your jurisdiction.

Children under the age of 18 are prohibited from using ESimTel’s services. We do not knowingly collect (or knowingly allow any third party to collect) Personal Data from persons under 18. If we become aware that we have collected data from a person under 18, we will delete it and terminate that individual’s account as quickly as possible.

11. Who Should I Contact?

ESimTel has a Data Protection Officer in accordance with applicable laws. If you have any questions about this Notice or would like to exercise your data protection rights, please contact our Data Protection Officer at dpo@esimtel.diploy.in or by filling out the form at the end of this page.

12. Updates to This Notice

We will make every effort to keep this Notice up to date. It will be regularly reviewed and may be amended and updated as necessary. Any updates will be posted in this section of the website.

This Notice is drafted in English. In the event of any conflict between this English version and any translated copies, the English version will prevail.