Privacy Policy

Effective date: 13 June 2024

Picom Technologies LTD, operating as 7G eSIM (www.7g.app) (“7G eSIM,” “we,” “our,” or “us”), values your privacy. This Privacy Policy explains how we gather, use, share, and safeguard your personal information, also known as personal data. It also informs you about your rights and choices regarding your personal information and how you can contact us with any questions.

By registering an account or using any 7G eSIM website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you agree to the terms of this policy.

This Privacy Policy details our data collection, use, disclosure, retention, and protection practices. Please read it carefully.

Scope of this Privacy Policy
How We Collect, Use, and Disclose Personal Information
Types of Information We Collect
Data Retention Policy
Use of Information
Sharing of Personal Information
Your Rights and Choices
International Data Transfers
Data Security
Policy Updates
Children’s Privacy
Contact Information
Additional Information for California Residents

1. Scope of this Privacy Policy

This Privacy Policy applies to all users of 7G eSIM services worldwide, including those using our mobile applications, Partner Platform, websites, features, and other services, as well as employees and job applicants (“Services”).

It outlines how 7G eSIM collects and uses data and applies to:

End Users: Individuals using Services via their 7G eSIM account for personal use.
Business Users: Entities that provide us with End Customer’s personal information in connection with their business activities.
End Customers: Individuals receiving services ordered by other 7G eSIM account owners.
Job Applicants: Individuals applying for jobs at 7G eSIM.

2. How We Collect, Use, and Disclose Personal Information

We gather information in various ways depending on your interactions with us and our Services, including:

Directly from you: When you register for an account, sign up for communications, place orders, make purchases, or contact us by phone, email, or otherwise.
Automatically: Using cookies, server logs, and other technologies when you interact with our Services and/or emails, where legally permissible or with your consent.
From other sources: Including affiliates, business partners, service providers, social media networks, and other third parties, or from publicly available sources.

7G eSIM as a Data Controller

As a data controller, 7G eSIM determines the purposes and means of processing personal data. We ensure compliance with applicable data protection laws. Activities under this capacity include:

Direct Sign-ups:
- B2C Context: End users registering for 7G eSIM’s services.
- B2B Context: Business Users or End Customers signing up directly with 7G eSIM.
Key Activities:
- Service Delivery: Providing our products and services.
- Fraud Prevention: Monitoring and detecting fraudulent activities.
- Legal Compliance: Adhering to legal and regulatory obligations.
- Service Enhancement: Improving products and services based on data analysis.
- Job Application Processing: Managing personal data from job applications.

7G eSIM as a Data Processor

In scenarios where we provide services on behalf of Business Users, we act as a data processor, following their instructions. This includes:

B2B Context for End Customers: Processing data related to End Customers of Business Users.
Service Execution for Business Users: Creating accounts and distributing eSIMs to End Customers.

3. Types of Information We Collect

We collect various types of data for different purposes, including:

Context	Types of Data	Primary Purpose
Account Registration	Name, contact information, actions performed while logged in.	Providing account-related functionalities, easy checkout, saving preferences, fulfilling contracts.
Biometric Information	Biometric identifiers from photo IDs and selfies.	Confirming identity through the eKYC process, with explicit consent where required by law.
Business Users	Name, contact information of Business User employees.	Contacting clients, normal business administration, projects, services, and billing.
Online Tracking	Information about browser type, operating system, IP address, domain name, click-activity.	Making our website operate efficiently.
Non-Essential Tracking	Information for analytics, interaction recording, behavior-based advertising.	Using third-party cookies based on consent where required by law.
Demographic Info	Personal information like age or location.	Understanding users and providing tailored services.
Job Applicants	Information necessary to process job applications or retain employees.	Evaluating potential employees, complying with legal obligations, efficient staffing, and workforce operations.
Feedback/Support	Name, email, and content of feedback or support queries.	Receiving and acting upon feedback or issues.
Mobile Devices	Unique identifying information broadcast from mobile devices.	Identifying unique visitors, monitoring website visits.
Order Placement	Name, billing/shipping address, email, phone number, payment card details.	Fulfilling orders and providing Services.
Partner Promotion	Information provided as part of a co-branded promotion.	Fulfilling promotions.
Surveys	Information provided through surveys, subject to third-party privacy policies if applicable.	Understanding opinions and collecting relevant information.

4. Data Retention Policy

We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements.

5. Use of Information

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our websites.
To provide products and services or process returns.
To improve our services and product offerings.
To streamline the checkout process.
To conduct analytics.
To communicate with you, such as responding to requests, inquiries, issues, or feedback.
To send marketing and promotional materials, including information about products, services, sales, or promotions, or those of our business partners.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violations of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
To debug, identify, and repair errors impairing existing intended functionality of our website and services.
To comply with our legal or regulatory obligations, establish or exercise our rights, and defend against legal claims.
For internal administrative purposes, as well as managing our relationships.
For such other purposes as you may consent to from time to time.

Although these sections describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase, we may collect your information to perform our contract with you, but we also collect it to maintain your information after your transaction is complete, enabling us to respond to questions about your order. Thus, our collection and processing of your information is based on your consent, our need to perform a contract, our legal obligations, and/or our legitimate interest in conducting our business.

6. Sharing of Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

Affiliates and Acquisitions: Sharing information with corporate affiliates or in the event of a business acquisition.
Other Disclosures without your consent: Disclosing information in response to legal requests, to establish or exercise our rights, to investigate illegal activities, fraud, or threats, or to comply with your request for third-party services.
Partner promotion: Sharing information during co-branded promotions with third parties.
Service providers: Sharing information with service providers for administrative, technical support, payment processing, and order fulfillment.
Other disclosures with your consent: Disclosing your information to third parties when we have your consent.

7. Your Rights and Choices

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

Access your data: Request disclosure of personal information we collect, use, or disclose, and information about our data practices.
Verify and seek rectification: Request correction of inaccurate personal information. You can update or delete your account profile on our website, or contact us to request modifications.
Have your personal information deleted: Request deletion of collected personal information.
Withdraw your consent: Withdraw consent for processing your personal information.
Object to processing: Object to the processing of your personal information if it’s based on a legal basis other than consent.
Online tracking: We do not currently recognize the “Do Not Track” signal.

Note that not all the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to verify your identity adequately. We will not discriminate against individuals exercising their privacy rights under applicable law.

How to Exercise Your Rights

To exercise any of the rights described above or to appeal a determination related to a data subject rights request, please contact us using the contact information below or via our Contact Us page.

Unsubscribing from Marketing Emails

Opt-out from marketing emails by using the unsubscribe function within your Profile Settings. Log into your account, navigate to your Profile settings, and turn “I’d like to receive promotional emails” on or off to save changes. Your email address will be opted out of email marketing communications as soon as possible.

Deleting Your Account

Delete your account using the “Delete Account” function within your Profile Settings. Log into your account, navigate to your Profile settings, and click the “Delete Account” button, confirming your intention. We will process the request without delay or within one month of receipt of the request.

Data Processing After Deletion Requests

In certain circumstances, 7G eSIM may be required by law to retain and process your Personal Data even after a deletion request or objection to processing, such as for legal obligations under Know Your Customer (KYC) and payment transaction details.

8. International Data Transfers

Our Services are accessible in Europe and abroad. Your information may be processed in countries with different privacy laws than your country of residence. We take steps to treat personal information using the same privacy principles that apply in the country where we first received your information. By submitting your personal information, you agree to its transfer, storage, and processing in countries other than your country of residence, including but not limited to the United States.

9. Data Security

We follow industry standards to protect your personal information. No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. Users are responsible for keeping their password and credentials secure. If you believe your interaction with us is no longer secure, please notify us immediately at [email protected].

10. Policy Updates

We reserve the right to change this Privacy Policy at any time. Material changes will be notified by prominently posting a notice on our website or sending an email. Review this policy whenever you visit our websites or applications. The effective date refers to the current version’s start date, and the last updated date indicates when the current version was last modified.

11. Children’s Privacy

Our Services are not intended for children under 13, and we do not knowingly collect personal information from minors under 16 without parental consent. Children under 13 should not provide personal information to us.

12. Contact Information

For any questions, comments, appeals, or complaints about our privacy practices, or to access this Privacy Policy in an alternative format due to a disability, please contact us at:

Email: [email protected]

If you are in the European Union or United Kingdom and are not satisfied with our response, you may have the right to lodge a complaint with your local supervisory authority.

13. Additional Information for California Residents

California law requires additional privacy disclosures for residents. If you are a California resident, the following applies in addition to the rest of the Privacy Policy.

California Shine the Light

For more information about the categories of personal information (if any) we share with third parties or affiliates for direct marketing, submit a written request using the contact information above.

Notice of Collection

The table below describes the categories of personal information we collect, disclose for a business purpose, “sell,” and/or “share” (as defined by California law). Note, we do not “sell” your personal information for money. We use cookies and tracking technologies for targeted advertising. See the Cookies and Other Technologies section for details.

Category of Personal Information	Category of Recipients	Disclosures for a Business Purpose	Sharing for Cross-Context Behavioral Advertising
Identifiers	Affiliates, Business partners, Data analytics providers, Internet service providers, Joint marketing partners, Operating systems, Other Service Providers, Payment processors, Professional services organizations, Social networks, Advertising networks	Yes	Yes
Government Issued Identification	Network operators (e.g., eKYC), Professional services organizations (e.g., auditors, law firms)	Yes	No
Financial Information	Operating systems, Payment processors, Professional services organizations (e.g., auditors, law firms)	Yes	No
Characteristics of protected classifications	Network operators (e.g., eKYC), Professional services organizations (e.g., auditors, law firms)	Yes	No
Commercial Information	Affiliates, Business partners, Data analytics providers, Internet service providers, Joint marketing partners, Operating systems, Other Service Providers, Payment processors, Professional services organizations, Social networks	Yes	Yes
Internet or other electronic network activity information	Data analytics providers, Advertising networks	Yes	Yes
Professional or employment-related information	Affiliates, Business partners, Operating systems, Other Service Providers, Professional services organizations (e.g., auditors, law firms)	Yes	No
Non-public education information	Affiliates, Business partners, Operating systems, Other Service Providers, Professional services organizations (e.g., auditors, law firms)	Yes	No
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Network operators (e.g., eKYC), Professional services organizations (e.g., auditors, law firms)	Yes	No

California Sensitive Information Disclosure

We collect the following categories of sensitive personal information (as defined under California law): biometric information, geolocation, social security number or other government-issued ID information, account log-in, payment information. This information is collected to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.

June 13, 2024