Last Updated: May 30, 2025

This Privacy Policy explains how Simply Communication LTD ("Simply", "we", "us", or "our") collects, uses, discloses, and protects your personal data when you use our website, mobile application, and any related services (together, the “Services”). By creating an account, accessing our platform, or purchasing and using data plans, you agree to this Privacy Policy. If you do not agree, please do not use our Services.

1. Information We Collect

We may collect the following categories of personal information, depending on how you use our Services:

a. Account Information

• Email address
• Name (optional)
• Authentication credentials or OAuth tokens (Google, Facebook, Apple)

b. Transaction & Usage Information

• Selected data plans, activation dates, duration
• Order status, time zone, currency, country of use
• IP address and device region

c. Device & Technical Information

• Device type, model, OS, OS version
• App version, device language, screen size
• App events (e.g., eSIM install attempts, login success/failure)
• Unique device identifier
• Network type and public ISP

d. Communication & Support

• Messages sent via email or in-app chat
• Details required to handle support requests (e.g., device info, plan details)
• IP address if contacting us via live chat

e. Referral Program

If you participate in our referral program, we may collect and process referral codes, referral activities, and rewards associated with your account.

f. Marketing Preferences

If you opt-in to receive marketing emails or app notifications, we collect your preferences (e.g., language, engagement behavior).

2. How We Use Your Information

We use your information to:

• Create and manage your account
• Authenticate logins via email or OAuth
• Deliver, activate, and manage eSIM data plans
• Process payments and issue refunds via Flitt (which may include Apple Pay or Google Pay)
• Send you service-related communications
• Respond to support requests and technical issues
• Improve our Services, app performance, and UI/UX
• Detect and prevent fraud or abuse
• Send marketing communications (only if you have consented)
• Administer referral program participation and benefits

3. Legal Bases for Processing

We rely on the following legal grounds to process your personal data:

• Contractual necessity – to provide and maintain our Services
• Consent – for sending marketing communications
• Legal obligation – to comply with applicable laws (e.g., taxation, accounting)
• Legitimate interests – to improve and secure our platform, prevent abuse, and support users efficiently

4. Sharing Your Information

We do not sell or rent your personal data. We may share your information with the following third parties under limited circumstances:

• Payment processors, including Flitt and their integrations (Apple Pay, Google Pay)
• Service providers, such as email delivery services, analytics platforms, crash reporting tools, or customer support platforms
• Legal and regulatory bodies, if required by law or to protect our rights
• Affiliates or business successors, in case of a merger, acquisition, or restructuring
• Referral program platforms, for reward tracking and processing

Each third party only receives the minimum necessary data and is bound by confidentiality and security obligations.

5. Your Rights

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

• Access – to request a copy of the personal data we hold
• Correction – to correct or update inaccurate or incomplete data
• Deletion – to request erasure of your personal data
• Restriction – to request limited use of your data
• Objection – to object to processing based on legitimate interest
• Portability – to receive your data in a structured, machine-readable format
• Withdraw Consent – at any time for marketing or optional processing

To exercise your rights, contact us at support@simplyesim.app. We may request identity verification.

6. Account Deletion

You may request deletion of your Simply account at any time.

How to delete your account:

• By emailing support@simplyesim.app from the email address associated with your account and requesting account deletion.

After verifying your request, we will permanently delete your account and associated personal data, except where retention is required by law (for example, transaction records for accounting or compliance purposes).

Deletion timeframe:
Account deletion requests are processed within 30 days.

7. Data Security

We implement appropriate technical and organizational measures to safeguard your personal data, including:

• Encrypted data transmission and secure storage
• Access controls and role-based authorization
• Firewalls, antivirus, and monitoring for intrusion attempts
• Routine software updates and vulnerability patching
• Staff training on data protection

However, no internet-based system is 100% secure. You acknowledge the risk of transmission over the internet.

8. Data Retention

We retain your personal data only as long as necessary for the purposes described above or to comply with legal requirements:

• Account & order data – up to 10 years (for legal/accounting)
• Usage logs – up to 3 years
• Support communication – up to 3 years
• Marketing consent – until you unsubscribe or withdraw consent
• Referral activity – while the account remains active

After expiration, we securely delete or anonymize your data.

9. International Data Transfers

We may transfer your data across countries where our service providers operate. In such cases, we implement appropriate safeguards (e.g., standard contractual clauses) to protect your data in line with applicable data protection laws.

10. Cookies & Tracking Technologies

Our website uses cookies and similar technologies for:

• Site functionality and language preferences
• Analytics and performance tracking
• Affiliate attribution
• Marketing (if consented)

You can manage cookie preferences in your browser. For more details, see our Cookie Policy (coming soon).

11. Children's Privacy

Our Services are not directed to anyone under the age of 18. We do not knowingly collect personal data from minors. If we learn we have done so, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy occasionally. If we make material changes, we will notify you via our app, website, or email. The “Last Updated” date will always reflect the current version. Continued use of our Services means you accept the changes.

13. Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or your data, you can contact us at:

📩 support@simplyesim.app