By registering an account or otherwise using or visiting any Re:SIM (EsimPlans) website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and agree to the terms of this policy. Please read this policy carefully.
The Service is provided by Privatix LTD, a company registered in the State of Israel and having its registered address at 150 Menachem Begin Road, WE Tower - Level 9, Tel Aviv 6492105. Additional business entities may be utilized for the provision of services, which may include but are not limited to TempLabs LLC, located at 30 N Gould St Ste R, Sheridan, WY 82801.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us directly at [email protected] or find more information under section ‘7. How Does A User Change Or Update Information’.
EsimPlans is committed to your privacy. This privacy notice explains how we collect, use, disclose, retain, and protect your personal information.
A few key principles regarding GDPR :
A clear purpose: The controller must specifically inform the customer of the use he will make of his personal data by collecting them.
Relevant data: The controller must only collect data that is strictly necessary for his treatment; this is the principle of minimizing collection.
The retention period:The personal data must be kept enough time to the controller to achieve its purpose; beyond that time, the data must be deleted.
The rights of individuals: Individuals can exercise their rights over the personal data held by the controller: access, rectification or deletion.
1. What Information Do We Collect?
1.1. Personally-Identifiable Information
We may collect personally identifiable information when you specifically and knowingly provide it to us, for example when you sign up for our newsletter or chat, create an account, request more information on our contact us page, respond to a survey or questionnaire and provide personal information such as your email address, name, phone number or other information. Where applicable, personally identifiable information includes personal data as defined in applicable law.
EsimPlans does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to identify a specific individual. We collect and use your personally-identifiable information to provide the services, operate and improve our service, provide customer service, perform research and analysis aimed at improving our products, service and technology, and display content that is customized to your interests and preferences.
You may always choose not to provide personally identifiable information, but if you choose so, certain parts of the Service may not be available to you. If you have registered an account with us, you will have agreed to provide your personally identifiable information in order to access the services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our Services.
1.2. Sensitive Personal Data
Subject to the following paragraph, we ask that you do not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit content to the services, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us. Please note that even if these information are provided, we will not store them anywhere on our side.
1.3. Non-Personally-Identifiable Information
We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information such as a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and durations. We also may collect navigational information, including information about the service content or pages you view, the links you click, and other actions taken in connection with the service. We use this information to analyze usage patterns as part of making improvements to the Service.
1.4. Cookies, Pixels and Local Storage
We may collect information using cookies, which are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
1.5. Stripe identifying information
2. Cookies We Use
2.1. Type of Cookies
The Services use the following types of cookies for the purposes set out below:
Strictly Necessary Cookies: These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the sites or applications and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow the Services to remember choices you make when you use a site or application, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of your account or preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.
Performance Cookies: These cookies are used to collect information about traffic to the services and how users use the services.The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to, the websites that referred them, the pages visited, what time of day they visited, whether they have visited before, and other similar information.We use this information to help operate the services more efficiently, to gather broad demographic information and to monitor the level of activity on our services.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: https://policies.google.com/privacy
You can prevent the use of Google Analytics relating to your use of the services by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout
Targeting Cookies / Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
2.2. Disabling Cookies
On www.youronlinechoices.com you can read more about cookies and the individual providers. There you can also opt out of usage-based online advertising through one or more tools. To go directly to the preference manager, please click here.
2.3. Facebook Custom Audiences
2.4. Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on the Services to track the actions of users on our sites and applications. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users personal data.
2.5. Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
3. Information That We Collect
EsimPlans will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:
To operate, maintain, and improve the Services;
To manage your account, including to communicate with you regarding your account;
To operate and administer any promotions you participate in on any site or application;
To respond to your comments and questions and to provide customer service;
To send information including technical notices, updates, security alerts, and support and administrative messages;
With your consent, to send you marketing emails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates.
We retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products or services, such as when you last opened an email from us.
We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
You may opt-out of receiving such information at any time: such marketing emails tell you how to opt-out. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
To process payments you make via the Services; and as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
We may share this information with service providers who perform services on our behalf, such as those services listed above, or other services like processing information requests, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.
We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). Re:SIM (EsimPlans) will provide you with information about EsimPlans’ data and how it will be used upon request. Should your data stored by Re:SIM (EsimPlans) be incorrect, Re:SIM (EsimPlans) will correct it. In this regard, you can write to Re:SIM (EsimPlans) at the address listed in section ‘7. How Does A User Change Or Update Information’ or contact them in any other way. In addition, customers can view the data in their account that Re:SIM (EsimPlans) has stored about them and correct it if necessary.
You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Services may be ineffective upon opt-out. You may also: (A) access the data we hold about you at any time via your account or by contacting us directly; (B) update or correct any inaccuracies in your personal data by contacting us; (C) in certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data. You may contact us at [email protected] anytime for any other questions you may have about your personally identifiable information and our use of it.
As a general rule, Re:SIM (EsimPlans) will not disclose any of your personally identifiable information except under one of the following circumstances:
We determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena;
It is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data;
Where we need to share your information to provide the product or service you have requested;
When such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by EsimPlans.
EsimPlans may share the non-personally identifiable information that Re:SIM (EsimPlans) gathers, in aggregate form only, with advertisers and other partners.
5. Children’s Policy
The Terms of service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. Re:SIM (EsimPlans) does not knowingly collect personally identifiable information from users under 13. In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database.
6. International Usage
The Service is owned by Privatix LTD and may be accessed in Israel, Europe and abroad. For data protection purposes, Re:SIM (EsimPlans) is the controller and, unless otherwise noted, is also the processor of data.
Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.
EsimPlans has also contracted with third party service providers to manage the logistics and customer support for an optimal service. Some data needs to be disclosed and transferred to these third party to ensure the fulfilment of the service. All third party involved have been engaged under a binding confidentiality agreement and have a limited access to Re:SIM (EsimPlans) database for the purposes of providing support.
7. Security and Encryption
We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at [email protected].
8. Privacy Rights
To request access and obtain a copy of your personal information, to request rectification or erasure,to restrict the processing of your personal information; and if applicable, to restrict data portability, to object to the storage of your personal information, under certain conditions.
To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information justified by lawful grounds other than consent.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
9. California residents privacy rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, certain rights and obligations apply regarding your personal information.
What categories of personal information do we collect? We may collect the following categories of personal information:
- Identifiers. Examples: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
- Personal information categories listed in the California Customer Records statute. Examples:
Name, contact information, education, employment, employment history and financial information
- Protected classification characteristics under California or federal law. Examples: Gender and date of birth
- Commercial information. Examples: Transaction information, purchase history, financial details and payment information
- Biometric information. Examples: Fingerprints and voiceprints.
- Internet or other similar network activity. Examples: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
- Geolocation data. Example: Device location.
- Audio, electronic, visual, thermal, olfactory, or similar information. Example: Images and audio, video or call recordings created in connection with our business activities.
- Professional or employment-related information. Example: Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
- Education Information. Examples: Student records and directory information.
- Inferences drawn from other personal information. Examples: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
EsimPlans has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Re:SIM (EsimPlans) will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
- Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
- Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a different communication method (e.g. phone or email) that you have previously identified to us. We may also use other verification methods as the circumstances require.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying your identity.
Other privacy rights
- you may object to the processing of your personal data
- you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
- you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us via the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
10. Changes to This Policy
11. Contacts regarding the policy
If you have questions or comments about this notice, you may contact us by email at any time. Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at [email protected]. We will respond to your request within 30 days.
Last update: May 1, 2023