Privacy Policy
Last updated: January 1, 2024
1. Introduction
This privacy policy ("Notice") is intended to inform you about the processing of your Personal Data by OneClickSIM Limited ("OneClickSIM", "we", "us" or "our") and also sets out the information, including the personal information detailed below, in relation to you or that you provide to us ("Personal Data"). This information will be collected and processed by OneClickSIM and/or on its behalf by its external service providers when you contact us through our channels, such as our application or website, once you have contracted our services. We are required to provide you with this information, as well as inform you of your data protection rights, in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").
Does OneClickSIM comply with data protection laws?
OneClickSIM takes its data protection obligations seriously and will never share personal data with third parties without the appropriate legal basis. We are committed to compliance with data protection and privacy regulations worldwide, including GDPR, UK data protection laws and relevant privacy frameworks in North America, Australia and Latin America, with privacy by design integrated into all our services.
2. OneClickSIM as Data Controller
For the purposes of this Notice, the controller of your personal data is OneClickSIM Limited, located at Grand Canal Square 2, 6th Floor, Dublin 2, D02 A342, Ireland. OneClickSIM is responsible for your Personal Data.
OneClickSIM is committed to respecting your fundamental right to the protection of your Personal Data and this Notice is intended to inform you about the processing we do of this data.
3. Types of Personal Data we process about you
| Category of Personal Data | Information |
|---|---|
| Website usage and device data: when you visit our application or website. | Your visits and interactions with our website, including the pages you visit, the 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 associated website you access through our website. Most of this Personal Data is collected through the use of cookies on the website. Visit our Cookie Policy for more information about how the website uses cookies. |
| Customer data: when you purchase an e-SIM or data plan. | Full name, position, country of residence, current location, address, network provider, phone number, payment information, email address, device type (e.g. brand and model), copy of your passport, driver's license or similar identification document (when necessary) and other information related to you when you interact with us in relation to the purchase of an e-SIM. |
4. Sources of your Personal Data
During the course of our contractual relationship or when you visit our website or application, we will collect your Personal Data in different ways: (1) directly from you, (2) indirectly from third parties (for example, through our affiliates or travel agencies once you have contracted our services).
When you browse our website, different cookies and other tracking tools may be installed on your device, as set out in our Cookie Policy. When we collect your Personal Data through the use of cookies on our website that are not necessary for its operation, we will ask for your prior consent to do so.
5. For what purpose and on what legal basis do we process personal data?
In the following table we present the key context under which ("Legal Basis") we process your Personal Data. We also explain how ("Nature of processing") we obtain and collect your Personal Data.
| Legal Basis | Nature of processing and purpose | Category of Personal Data |
|---|---|---|
| Compliance with legal obligation | OneClickSIM may process your Personal Data when necessary to comply with legal obligations to which we are subject under European Union and/or applicable laws, including, among others, safeguarding and compliance with law enforcement requests. | Customer data; Website data |
| Performance of a contract | Provide you with access to the website and allow you to use it. Manage the purchase of the e-SIM or data plan that we sell on our website and the payment related to such products. Calculate and issue charges for services provided to you. Review and handle incidents, inquiries, complaints or requests from customers in relation to our products and services. Manage and carry out any type of after-sales service. Manage your registration as a user on our website and/or application, as well as allow you to access the private user area of OneClickSIM. | Customer data; Website data |
| Legitimate interest | Facilitate the use of your e-SIM or data plan, including managing your account, and provide you with customer service. Better understand how our customers use our website to improve it. Personalize products and services for you and, if you give your consent to direct marketing, personalize direct marketing. Monitor and prevent cybersecurity issues and unauthorized use of our information, systems and/or computer equipment. Streamline our business processes through the use of external platforms. Carry out internal business reviews and, if necessary, contact the customer in the event that fraud or identity theft is detected or there are reasonable suspicions of fraud, identity theft or illegal activities. Record calls for training purposes and to improve our customer service. Carry out any other activity necessary for the development of our business, including system testing, network monitoring, staff training and quality control. | Customer data; Website data |
6. Who do we share your Personal Data with?
Depending on the purpose for which we process your Personal Data, we may share it, to the extent necessary, with some or all of the following recipients:
- Internal/intragroup entities of OneClickSIM: internal departments and services (such as our Sales Department, Marketing Department or IT Department).
- Telecommunications service providers: service providers located in the corresponding jurisdiction in which the e-SIM service was purchased.
- Regulatory authorities and law enforcement agencies: When we have a duty to disclose or share your Personal Data to comply with any legal or regulatory obligation or request, such as, for example, with the tax agency, the Ministry of Social Protection, the Data Protection Commission, the Labor Relations Commission, the Irish courts, An Garda Síochána (National Police of the Republic of Ireland) or any other applicable authority.
- External advisors/professionals: professional advisors who provide us with professional services, such as consultants and legal advisors.
- External service providers: We contract with external providers who may process your Personal Data on our behalf for the purposes mentioned. These include the following:
- Administrative services.
- Advertising and communication services.
- Corporate social responsibility services.
- Maintenance services.
- Physical security services.
- Filing, custody, storage and digitization services.
- Document withdrawal and destruction services.
- Back office services.
- IT services.
Does OneClickSIM share customer data with third parties?
"Our network operators only process the minimum technical information necessary for the service to function, such as IMSI (International Mobile Subscriber Identity), MSISDN (mobile number identifier) and IP addresses used to establish the connection. This information is standard in all mobile services worldwide and is necessary to route traffic and enable connectivity.
Our network partners only access the technical data required for connectivity and cannot see details such as names, emails, payment information or browsing activity. All communications use end-to-end encryption (HTTPS, SFTP, SSH), ensuring that data remains encrypted during transmission. We apply data minimization principles and maintain strict agreements with partners to prevent internet traffic from being linked to identifiable individuals."
7. International Data Transfers
Users resident in the European Union should note that their Personal Data will be transferred to certain recipients (mainly to our external service providers) who are located outside the European Economic Area ("EEA"), in countries with laws and practices that do not have equivalent data protection rights for their Personal Data (e.g. Thailand, Colombia...). In the event that such transfers occur, we ensure that appropriate safeguards exist to ensure that: a) transfers are not made without our prior written authorization; and b) there is an appropriate transfer mechanism, such as Module 2 of the Standard Contractual Clauses (approved by the European Commission) or a European Commission adequacy decision to protect your Personal Data. If you would like to know more about any transfer that may affect your Personal Data, please contact us at dpo@oneclicksim.com.
8. Your Data Protection Rights
| Right | Detailed Information |
|---|---|
| Right of access | You have the right to request a copy of the Personal Data that OneClickSIM has about you and to access the Personal Data we store about you. |
| Right to object | You have the right to object at any time to the processing of your Personal Data when OneClickSIM processes it on the legal basis of pursuing its legitimate interests. |
| Right to rectification | You have the right to have any inaccurate Personal Data that OneClickSIM has about you updated or corrected. |
| Right to erasure | In certain circumstances, you may even have your Personal Data deleted. For example, if you exercise your right to object and OneClickSIM does not have a primary reason to process your Personal Data or if it no longer needs your Personal Data for the purposes set out in this Notice. |
| Right to restriction of processing | You have the right to ask OneClickSIM to restrict the processing of your Personal Data in certain cases, for example, if you consider that the Personal Data we have about you is inaccurate or if the use of your Personal Data is unlawful. |
| Right to data portability | You may request OneClickSIM to provide you with the Personal Data that you have provided to it 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 in the place where the alleged infringement occurred. The relevant supervisory authority in Ireland is the Data Protection Commission, Ireland's 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 of your data, including profiling, which produces legal effects on the data subjects or similarly significantly affects them. We may not be able to comply with this request when the processing is necessary to enter into or perform our contract with them or when the processing is authorized under a law to which we are subject. |
9. How long we retain your Personal Data
In general, we store your Personal Data in accordance with our obligations under applicable Irish and European Union legislation and/or for the duration of our relationship with you, as well as for a reasonable period after this relationship ends. Your Personal Data will be stored for as long as necessary for the purpose(s) for which it was obtained. The criteria used to determine retention periods include:
- the duration of the contractual relationship plus 7.5 years from the date of termination;
- if retention is prudent in light of OneClickSIM's legal position (such as with respect to statutes of limitations, litigation or regulatory investigations);
- if OneClickSIM is subject to any legal obligation; and/or
- 6 months for connection history and call recordings.
What is OneClickSIM's data retention procedure?
OneClickSIM retains customer data only for the time necessary to provide the service and comply with legal obligations. Once this period has ended, the data is securely deleted or anonymized, in line with GDPR, the world's strictest privacy regulation, providing customers with the highest level of protection.
10. Personal Data of Minors
OneClickSIM understands the importance of safeguarding the Personal Data of minors, which we understand to be those individuals under 18 years of age in Ireland or the equivalent age specified by law in your jurisdiction.
Minors under 18 years of age are prohibited from using OneClickSIM's services. We do not knowingly collect (nor do we knowingly allow a third party to collect) Personal Data from persons under 18 years of age. If we become aware that Personal Data has been collected from a person under 18 years of age, we will delete such Personal Data and deactivate that individual account as soon as possible.
11. Who should I contact to exercise my data protection rights or for any inquiry related to my Personal Data?
OneClickSIM has a Data Protection Officer in accordance with applicable legislation. If you have any questions about the information detailed in this Notice or wish to exercise your data protection rights, please contact our Data Protection Officer at dpo@oneclicksim.com or complete the form located at the end of this page.
12. Updates to this Notice and other information
We will do our best to keep this Notice up to date. This Notice will be reviewed regularly and may be modified and updated periodically when necessary. Any update to this Notice will be published in this section of the website.
This Agreement is written in English. In case of conflict between this English version of the Notice and any translated copy thereof, the English version shall prevail.
This Privacy Policy has been reviewed and published on January 1, 2024.