Last Updated: April 27, 2022
California Residents: If you reside in California, please see our California Privacy Rights section below for further information on your rights under the California Consumer Privacy Act.
You may withdraw your consent at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal may restrict our ability to provide the Services. There are limited circumstances in which we may collect, use or disclose personal information without your consent. They include: a) when the collection, use or disclosure of personal information is permitted or required by law; b) in an emergency that threatens an individual’s life, health or personal security; c) when the personal information is available from a public source; d) when we require legal advice from a lawyer; e) for the purposes of collecting debt; f) to protect ourselves from fraud; or g) to investigate an anticipated breach of an agreement or a contravention of law.
3. How We Collect Information
We collect information about you from a variety of sources when you access our Website or Services, including: a) directly from you (when you sign up for or use our Services); b) from our business partners and service providers; c) from third party sources; and d) automatically from devices that you use to connect to our Website or Services.
4. Types of Information We Collect
The amount and type of information that we collect about you depends on the nature of your interaction with our Website and Services. We collect information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with us. We collect the following information based on different scenarios of usage while accessing our Services:
a) Registration/Profile Information
when signing up for your account, we collect your email address and password; passwords are hashed and encrypted before being transmitted to our servers; we do not see the clear text version of your password;
b) Contact Information
i. authentication information (e.g. your account’s email address and encrypted password);
ii. communications with us (e.g. interaction with our sales or customer support teams); and
iii. when purchasing data plans from certain countries, we may ask you to submit proof of identity and/or address verification information in order to comply with the requirements of local regulations in the territories from which the phone number(s) originate; we may share that information with our third party telecommunication providers in order to fulfill the transaction requirements and provide the phone number to your account.
c) Usage Information
i. like most website and app operators, we collect information about your interactions with the Website and Services, such as which screens or pages you visit, what you click on, when you perform those actions, language preferences, and so on);
ii. CDR (Charging Data Records) are stored to operate, maintain, and improve the Services that are provisioned to your account (CDRs contain various attributes of data usage, such as time, eSIM ICCID, data usage amount, country, and mobile network); and
d) Billing Information
i. payment information is collected by our third party payment provider Stripe, which may require you to provide your billing details and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). In most cases, we will have access to transaction reference numbers and/or your billing information pertaining to each payment; however, we do not store or otherwise process any credit card information. For more information regarding the manner in which Stripe collects your information, please visit: https://stripe.com/us/privacy
e) Information from Third Parties and Integration Partners
i. we collect your information or data from third parties if you give permission to those third parties to share your information with us or where you have made that information publicly available online; and
ii. other sources (to the extent permitted by applicable law we may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks).
f) Log Data
i. we collect log data each time a device accesses our servers, log data includes details about the nature of each access including originating IP addresses, access times, device type, operating system versions, internet service providers, pages you view before and after using the Website or Services, links to third party applications, and hardware and software information.
5. How We Use the Information We Collect
6. How We Share the Information We Collect
a) within our organization;
b) with our third-party service providers, affiliates and trusted key partners who help us provide certain aspects of our Services, including without limitation:
i. facilitate payment processing;
ii. facilitate sending customer email surveys or marketing notifications;
iii. manage our sales and customer support services to you;
iv. deliver and help us track our marketing and advertising content;
v. help us provide core features of telecommunications services;
vi. help us track website conversions and success metrics;
c) certain information may be shared with third parties or published when you follow links to third party websites, we do not own or control these third parties and when you interact with them you may be providing information to them directly – such parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and we encourage you to review these rules and policies;
d) information that you choose to share publicly or with others may be indexed through third party search engines – we do not control the practices of third party search engines so you need to be careful about the information you make public;
e) at your request or with your consent;
f) as required by applicable laws and related rules and regulations;
g) with a buyer, investor, new affiliate, or other successor in the event we or any affiliate undergoes a business transaction, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of our assets or any affiliates or during steps in contemplation of such activities (e.g. negotiations and due diligence);
h) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
i) we may collect statistics about the behavior of visitors to our Website. We may display this information, in aggregated form, publicly or provide it to others.
7. Retention of and Access and Change to Personal Information
We will only retain personal information that we collect for as long as is necessary and in accordance with applicable laws.
You may request access to your personal information or request to know how we use it or to whom it has been disclosed, subject to limited exceptions prescribed by law. Requests must be made in writing via e-mail to email@example.com. We will respond to requests within 45 days or provide notice if we require longer. To the extent permitted by applicable law, fees may be charged to access information, but you will be notified of such in advance so you can choose whether or not to proceed.
8. Security of Personal Information
We use appropriate security measures when we destroy personal information.
We routinely review and update our security policies and controls to ensure ongoing personal information security, though the Internet is not a 100% secure environment so we cannot guarantee the complete security and protection of the transmission and storage of your information.
9. Accuracy of Personal Information
We make reasonable efforts to ensure your personal information is accurate and complete. You may make a request to update, correct, or delete your personal information at any time by submitting a request in writing to firstname.lastname@example.org. It is your responsibility to provide updates to your personal information and to maintain its accuracy.
10. Safety of Minors
We encourage parents and guardians to be aware of their children’s online activities. We do not knowingly collect the personal information of minors (persons under the age of 13 or under a higher age if permitted by the laws of their residence). If you are aware that a minor has provided us with personal information, please contact us at email@example.com. If it comes to our attention that we have collected personal information from a minor, we may delete this information without notice.
We will not respond to Web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see https://youradchoices.com/
Because we link to social media sites, and from time to time may include third-party advertisements, other parties may collect your personally identifiable information about your online activities over time and across different web sites when you visit our Website.
Please note that not all tracking will stop even if you delete cookies.
12. Limitation of Liability
13. Questions and Complaints
15. Additional Rights
- “Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and
- “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Our legal basis for the processing of Personal Data are: (i) consent or (ii) any other applicable legal basis, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of the Services, preventing fraud, ensuring information and network security, direct marketing and advertising, and complying with industry practices.
Additional Rights for European Residents. As a resident of the European Union or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights:
- Access. To request a copy of the Personal Data we have collected about you by contacting us.
- Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
- Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
- Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.
- Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
- Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services.
- Right to Lodge a Complaint with a data protection authority. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority.
To exercise any of the above listed rights, please contact us as set forth below and provide sufficient details so that we can respond appropriately. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the individual submitting a request before we can address such request.
Compelled Disclosures. AffinityClick may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Data Protection Contact. Unless otherwise specified, AffinityClick is the data controller with respect to the data provided through the Services and the Website. Our Data Protection Contact for the Personal Data collected in connection with the Services is:
Attn: Privacy Team
CALIFORNIA PRIVACY RIGHTS | FOR CALIFORNIA RESIDENTS ONLY
Sale of Information: We have not disclosed and/or sold personal information to third parties for a business or commercial purpose in the preceding 12 months. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
If you wish to change personally identifiable information that you have provided us, please Contact Us.
Your Rights: You have the right to request that we disclose to you what information we collect, use, disclose, and sell. You also have the right to request that a business delete any personal information about you which the business has collected about you.
To submit either of the above requests, you may call us at 1-877-278-3625 or contact us via email at firstname.lastname@example.org. Please note for your protection, any request sent to us to delete your personal information will be subject to the following verification procedure: you are required to provide the last four digits of your credit card used to make a purchase. Also, please note that we only delete accounts with a valid “from” email address (i.e. you must request your data deletion from the same email used for your account). You have the right to direct us to not sell your information.
If you opt to exercise your privacy rights, we are required to verify your identity in order to prevent unauthorized access of your data. This may require us to ask you certain questions to confirm your identity or require you to provide state-issued identification. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of the reasons we are unable to honor your request.
Right to Know and Access Information: You may access information we maintain about you using the methods provided below. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law.
Deletion of Information: You may request that we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in ours business records. You may submit a deletion request using the methods provided below.
We shall not discriminate against you for exercising any of your above rights.
You may designate an authorized agent to make a request to exercise your rights on your behalf. For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.
We has no actual knowledge that it sells personal information of minors under age 16.