Privacy Policy

MIRAXIS LTD is the controller of personal data processed for the purposes described in this Policy, except where another organisation acts as an independent controller for its own processing activities.

If you have questions about this Policy or wish to exercise a data protection right, you can contact us at [email protected].

SimConnecta is intended only for persons aged 18 or over. You must be at least 18 years old to create an account or use our services.

We do not knowingly offer our services to children. If we become aware that personal data has been provided by a person under 18 in connection with an account or use of our services, we may restrict or close the account and take appropriate steps in relation to the personal data, subject to applicable law.

Depending on how you use SimConnecta, we may collect the following categories of personal data:

* Account and identity data, such as your name, date of birth where requested, account identifier, username and login-related information.
* Contact data, such as your email address, telephone number and other contact details you provide.
* Transaction data, such as eSIM orders and the packages included in them, purchases, refunds, transaction identifiers, dates, amounts, currency and payment status.
* Payment-related data, such as limited payment method information, payment status, currency and payment-provider references. Full payment card details may be collected directly by our payment service providers rather than stored by SimConnecta.
* eSIM and service data, such as eSIM plan information, destination, activation status, usage-related service information made available to us, installation or fulfilment status and technical support history.
* Identity verification data, where reasonably required to confirm age, verify an account or payment, prevent fraud or meet applicable legal or payment-provider requirements. This may include identity document images, document type, document number where processed, issuing country, expiry date and verification status.
* Device and technical data, such as IP address, browser type, device type, operating system, language, time zone, identifiers, diagnostic information and security logs.
* Usage data, such as pages viewed, actions taken on the Website, session information, interactions with features and other information about how the Website is used.
* Support and communications data, including emails, support requests, complaint information and information you provide when communicating with us.
* Marketing and preference data, such as marketing preferences and consent choices where applicable.
* Cookie and similar technology data, as described in our Cookie Policy.

We may collect personal data:

* directly from you when you register, select an eSIM package, add it to the shopping cart, pay for an order, submit information, contact us or request a refund;
* automatically when you use the Website, including through server logs, cookies and similar technologies;
* from payment service providers, where they provide transaction status, limited payment details, fraud signals or other information necessary to process or secure a transaction;
* from eSIM and telecommunications suppliers where necessary to fulfil, activate, troubleshoot or support an eSIM service;
* from identity verification providers where they are used to verify identity, age or payment-related information for security, fraud prevention or applicable legal or payment-provider requirements;
* from fraud-prevention, security and technical service providers.

We must have a lawful basis for using personal data. The lawful basis depends on the purpose for which the data is processed.

We may process personal data for the following purposes:

* To create and manage your account, authenticate you and provide account functionality. Lawful basis: performance of our contract with you.
* To process direct purchases, record the eSIM package or packages included in each order, associate each payment with the relevant order, fulfil eSIM orders, provide activation details and deliver purchased services. Lawful basis: performance of our contract with you.
* To verify identity, age or payment-related information where reasonably necessary to protect accounts, prevent fraud or meet applicable legal or payment-provider requirements. Lawful basis: our legitimate interests in secure transactions and fraud prevention, and legal obligations where applicable.
* To process payments, refunds, payment disputes and chargebacks. Lawful basis: performance of our contract, compliance with legal obligations where applicable and our legitimate interests in managing transactions and preventing abuse.
* To provide technical support, respond to enquiries, complaints and service requests. Lawful basis: performance of our contract and our legitimate interests in customer support and service administration.
* To detect, investigate and prevent fraud, unauthorised use, account takeover, payment abuse and security incidents. Lawful basis: our legitimate interests in protecting users, our business and the integrity of the Platform, and legal obligations where applicable.
* To maintain the security, availability and functionality of the Website and our systems, including logging and troubleshooting. Lawful basis: our legitimate interests in operating a secure and reliable service.
* To maintain accounting, tax, corporate and transaction records. Lawful basis: compliance with legal obligations and our legitimate interests in record keeping and the establishment, exercise or defence of legal claims.
* To comply with binding legal requests, court orders, regulatory requirements or other legal obligations. Lawful basis: compliance with a legal obligation.
* To send direct marketing where permitted. Lawful basis: consent where required, or legitimate interests where direct marketing is permitted without consent. You can opt out at any time.
* To use non-essential cookies or similar technologies. Lawful basis: consent where required by applicable law.

Where we rely on legitimate interests, we consider whether the processing is necessary for the relevant purpose and whether your interests, rights or freedoms override those interests.

Our legitimate interests may include:

* preventing fraud and misuse of the Platform;
* protecting accounts, eSIM orders and payment transactions;
* securing purchases and preventing unauthorised use of payment methods;
* maintaining and improving service reliability and security;
* responding to users and managing customer support;
* establishing, exercising or defending legal claims; and
* operating our business efficiently and protecting it against abuse.

We may request identity, age or payment-related information where reasonably necessary to protect account security, verify a payment, prevent fraud or satisfy applicable legal or payment-provider requirements.

For these purposes, we may collect and process a valid government-issued identity document and associated identity information where reasonably required. This information is used to verify the relevant user or payment, reduce fraud and unauthorised activity, meet applicable payment-provider requirements and comply with applicable legal obligations where they apply.

We may request additional information where reasonably necessary to complete verification or resolve an identity, security or fraud concern.

We do not use identity documents for unrelated advertising or marketing purposes.

Payments may be processed by third-party payment service providers. Depending on the payment method, you may provide payment information directly to the relevant provider.

SimConnecta may receive limited information from payment providers, such as payment status, transaction reference, amount, currency, payment method type, limited card information where made available, and fraud or authentication results.

We do not intentionally store full payment card numbers or card security codes where these are collected and processed directly by our payment providers.

We may share personal data with the following categories of recipients where necessary:

* payment service providers, acquirers and banks;
* identity verification and fraud-prevention providers;
* eSIM suppliers, telecommunications providers and technical fulfilment partners;
* cloud hosting, infrastructure, security, analytics and IT service providers;
* customer support and communications service providers;
* professional advisers, including legal, accounting, audit and compliance advisers;
* courts, regulators, public authorities, law enforcement bodies or other parties where disclosure is required or permitted by law;
* potential buyers, investors, lenders or advisers in connection with a genuine corporate transaction, subject to appropriate confidentiality and legal safeguards.

Service providers acting on our behalf are expected to process personal data only for authorised purposes and subject to appropriate data protection and security obligations.

We do not sell personal data.

Some of our service providers or business partners may process personal data outside the United Kingdom.

Where personal data is transferred internationally, we use a lawful transfer mechanism where required. Depending on the destination and circumstances, this may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another transfer mechanism permitted by applicable data protection law.

You may contact us at [email protected] for further information about the safeguards used for relevant international transfers.

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, including to provide the services, maintain transaction and accounting records, manage disputes, prevent fraud, satisfy legal or payment-provider requirements and establish, exercise or defend legal claims.

When deciding how long to retain data, we consider:

* the nature and sensitivity of the data;
* the purpose for which it was collected;
* the duration of the account or customer relationship;
* applicable tax, accounting, corporate, consumer protection and limitation periods;
* fraud-prevention and security needs;
* payment-provider and eSIM supplier requirements; and
* whether the data is needed for an actual or potential dispute or legal claim.

Identity verification documents are retained only for as long as necessary for verification, fraud prevention, applicable provider or legal requirements and dispute management. They are not retained indefinitely merely because they were uploaded.

When personal data is no longer required, we will delete, anonymise or securely dispose of it, subject to any continuing legal or legitimate retention requirement.

We use cookies and similar technologies for purposes such as essential Website functionality, security, remembering preferences, performance measurement and, where enabled, analytics or marketing.

Non-essential cookies are used only in accordance with applicable consent requirements. More information is available in our Cookie Policy.

Where permitted, we may use your contact details to send information about SimConnecta services, offers or updates.

You can opt out of direct marketing at any time by using the unsubscribe mechanism in the relevant communication, changing available preference settings, or contacting us at [email protected].

If you opt out, we may retain limited suppression information to ensure that your marketing preference is respected.

We may use automated rules or risk signals to identify potentially fraudulent, unauthorised or abusive activity, including suspicious payments, orders or account access.

Where a decision with legal or similarly significant effects is based solely on automated processing and applicable law gives you specific rights in relation to that decision, we will provide the required information and safeguards.

Where appropriate, a transaction or account may be referred for manual review.

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

Measures may include, as appropriate:

* access controls and authentication;
* encryption or secure transmission methods;
* security logging and monitoring;
* restricted access to identity verification and payment-related information;
* supplier and processor controls;
* fraud detection and account-security measures; and
* procedures for identifying and responding to security incidents.

No online service can guarantee absolute security. Users are also responsible for protecting their account credentials and notifying us promptly if they suspect unauthorised access.

Depending on the circumstances and the lawful basis for processing, you may have the following rights under applicable data protection law:

* Right of access - to request confirmation of whether we process your personal data and to obtain a copy of relevant personal data.
* Right to rectification - to ask us to correct inaccurate or incomplete personal data.
* Right to erasure - to ask us to delete personal data in circumstances where the right applies.
* Right to restriction - to ask us to restrict the use of personal data in certain circumstances.
* Right to data portability - to receive certain personal data you provided to us in a structured, commonly used and machine-readable format, or to ask that it be transferred to another organisation, where the right applies.
* Right to object - to object to processing based on legitimate interests in certain circumstances.
* Right to object to direct marketing - you may object to the use of your personal data for direct marketing at any time.
* Right to withdraw consent - where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing carried out lawfully before consent was withdrawn.
* Rights relating to solely automated decisions - where applicable law provides such rights.

These rights are not absolute and may be subject to legal conditions, exemptions and limitations.

To exercise a data protection right, contact us at [email protected] and describe the request.

We may request information reasonably necessary to verify your identity before disclosing or changing personal data.

We will respond within the period required by applicable law. In many cases this is one month, although the time may be extended where permitted for complex or multiple requests.

You will not normally be charged for exercising your rights. A fee may be permitted in limited circumstances provided by law.

Where we process personal data on the basis of legitimate interests, you have the right to object in certain circumstances. If you object, we will stop the relevant processing unless we have compelling legitimate grounds to continue or the processing is required for the establishment, exercise or defence of legal claims.

You have an absolute right to object to the use of your personal data for direct marketing.

If you have concerns about how we use personal data, please contact us first at [email protected] so that we can investigate the matter.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) or, where applicable, another competent data protection authority.

Information about making a data protection complaint to the ICO is available at ico.org.uk.

The Website may contain links to third-party websites or services. We are not responsible for the privacy practices of independent third parties. You should review the privacy information provided by the relevant third party before providing personal data.

We may update this Policy where reasonably necessary to reflect changes to our services, data processing activities, providers, security practices or applicable law.

Where a change materially affects how we use personal data, we will provide appropriate notice where required by law.

The current version will be published on simconnecta.com with its effective date.

MIRAXIS LTD
Company Number: 17460571
Registered Office: 167-169 Great Portland Street, 5th Floor, London, United Kingdom, W1W 5PF
Website: simconnecta.com
Privacy & General Enquiries: [email protected]
eSIM & Technical Support: [email protected]
Telephone: +44 7537 132358