Privacy Policy

7G Communication, LLC, 131 Continental Drive, Newark, Delaware 19713, United States, 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.

Table of Contents

1. Scope of this Privacy Policy
2. How We Collect, Use, and Disclose Personal Information
3. Types of Information We Collect
4. Legal Bases for Processing (EEA, UK, Switzerland)
5. Cookies and Similar Tracking Technologies
6. Data Retention Policy
7. Use of Information
8. Sharing of Personal Information
9. Subprocessors and Third-Party Services
10. Automated Decision-Making and AI
11. Your Rights and Choices
12. International Data Transfers
13. Data Security
14. Policy Updates
15. Children's Privacy
16. Region-Specific Disclosures (EEA, UK, Switzerland, Brazil)
17. Contact Information and EU/UK Representative
18. Additional Information for U.S. State 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:

4. Legal Bases for Processing (EEA, UK, Switzerland)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, our processing of your personal data is based on one or more of the following legal bases under the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection (FADP):

5. Cookies and Similar Tracking Technologies

We and our service providers use cookies, software development kits (SDKs), pixels, local storage, mobile advertising identifiers, and similar technologies to operate our website and App, remember your preferences, secure your account, measure performance, and (where you consent) deliver personalized content and advertising.

We use the following categories of cookies and similar technologies:

• Strictly necessary: Required for the website and App to function, such as authentication, security, load balancing, and storing your consent choices. These cannot be switched off.
• Functional: Remember your preferences, language, and region to provide a personalized experience.
• Analytics and performance: Help us understand how visitors interact with our Services so we can improve them (e.g., Firebase Analytics, Google Analytics).
• Advertising and targeting: Used by us or our advertising partners to deliver ads relevant to your interests and to measure ad performance across sites and devices (e.g., Meta Pixel, Google Ads).

Where required by law, we obtain your consent before placing non-essential cookies or similar technologies through a consent management banner. You can withdraw or modify your consent at any time using the cookie-preferences control on our website. You can also manage cookies through your browser settings and reset your advertising identifier through your device's privacy settings. Disabling certain cookies may affect the functionality of our Services. We do not currently respond to browser “Do Not Track” signals, but we do honor Global Privacy Control (GPC) signals where required by law.

6. 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.

Typical retention periods are summarized below and may be longer where required by law:

When personal data is no longer required, we securely delete, anonymize, or aggregate it so that it can no longer be associated with you.

7. 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.

8. 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.

9. Subprocessors and Third-Party Services

To deliver the Services we rely on a network of trusted third-party providers (“subprocessors”) who process personal data on our behalf under written data-processing agreements. Categories include:

• Cloud infrastructure and hosting: e.g., Google Cloud Platform, Amazon Web Services, Cloudflare.
• Mobile network operators and eSIM platform providers: Carriers and roaming partners that provision and route connectivity for your eSIM.
• Payment processors: e.g., Stripe, PayPal, Apple Pay, Google Pay, and other regional acquirers.
• Identity verification and fraud prevention: eKYC and AML providers used when required by law or risk policy.
• Communications and customer support: Email, push-notification, SMS, and helpdesk providers (e.g., Intercom).
• Analytics and performance: e.g., Firebase, Google Analytics.
• Advertising and attribution: e.g., Google Ads, Meta, TikTok, and other ad networks (only where you have consented in regions that require consent).
• Professional advisors: Auditors, lawyers, accountants, and consultants bound by confidentiality.

Business Users can request an up-to-date list of subprocessors used in connection with their account by contacting office@7g.app. We perform reasonable due diligence on our subprocessors and require them to implement appropriate technical and organizational measures to protect personal data.

10. Automated Decision-Making and AI

We use automated systems, including rule-based engines and machine-learning models, to support certain Service operations such as fraud and abuse detection, transaction risk scoring, eligibility for postpaid credit limits, eKYC document checks, and content moderation. These systems help us protect our users and comply with legal obligations.

In limited cases, an automated decision may have a legal or similarly significant effect on you (for example, declining a transaction suspected of fraud or suspending an account that triggers a high-risk signal). Where required by Article 22 of the GDPR/UK GDPR or comparable laws, we ensure that you can: (a) request human review of the decision; (b) express your point of view; and (c) contest the decision. To exercise these rights, contact office@7g.app.

We use generative-AI tools internally for productivity, support summaries, and content drafting. Personal data is not used to train third-party general-purpose AI models, and any use of AI by 7G eSIM is subject to our internal AI governance standards, including data minimization, security, and applicable law (such as the EU AI Act). We do not sell your personal data and do not share it with third parties for the purpose of training their AI models.

11. 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.

12. 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.

Where we transfer personal data from the EEA, the United Kingdom, or Switzerland to a country that has not received an adequacy decision from the European Commission or the relevant authority, we put appropriate safeguards in place, including the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, and supplementary technical and organizational measures where required. You can request a copy of the safeguards we use by contacting office@7g.app.

13. 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 office@7g.app.

14. 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.

15. 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. If you believe a child has provided us with personal information without appropriate consent, please contact us at office@7g.app and we will promptly delete the data.

16. Region-Specific Disclosures

European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, the UK, or Switzerland, the GDPR, UK GDPR, or Swiss FADP (as applicable) grants you the rights set out in Section 11 above, including the right to access, rectify, erase, restrict, or object to the processing of your personal data; the right to data portability; the right to withdraw consent; and the right to lodge a complaint with your local supervisory authority. The legal bases on which we rely are set out in Section 4 above. For transfers outside the EEA/UK/Switzerland, see Section 12.

United Kingdom Representative

Where required by Article 27 of the UK GDPR, our UK representative can be contacted at office@7g.app with the subject line “UK GDPR Representative.”

EU Representative

Where required by Article 27 of the EU GDPR, our EU representative can be contacted at office@7g.app with the subject line “EU GDPR Representative.”

Brazil (LGPD)

If you are a data subject in Brazil, the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, “LGPD”) grants you rights including confirmation of processing, access, correction, anonymization, blocking or deletion, portability, information about sharing, and revocation of consent. To exercise these rights, contact office@7g.app.

Israel

If you are located in Israel, you may have rights under the Israeli Protection of Privacy Law, 5741-1981, including the right to access and request correction of personal data held about you.

Canada (PIPEDA)

If you are located in Canada, you may have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, including the right to access and request correction of personal data held about you.

17. Contact Information and EU/UK Representative

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 our privacy team at:

• Email: office@7g.app
• Postal address: 7G Communication, LLC, Attn: Privacy Team, 131 Continental Drive, Newark, Delaware 19713, United States.
• EU/UK Representative: See Section 16 above.

If you are in the European Union, the United Kingdom, or Switzerland and are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority. You also have the right to seek a judicial remedy against us where you believe your data-protection rights have been infringed.

18. Additional Information for U.S. State Residents

This section provides additional disclosures for residents of U.S. states that have enacted comprehensive consumer-privacy laws, including California (CCPA, as amended by the CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), and similar laws in other states. If you are a resident of one of these states, the rights described below supplement the rights and information provided elsewhere in this Privacy Policy.

Your U.S. State Privacy Rights

• Right to know / access: Request confirmation that we process your personal information and obtain a copy of the categories and specific pieces of personal information we have collected about you.
• Right to delete: Request deletion of personal information we have collected from you, subject to legal exceptions.
• Right to correct: Request correction of inaccurate personal information.
• Right to opt out of sale or sharing: Opt out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising (we honor Global Privacy Control signals where required by law).
• Right to limit use of sensitive personal information (where applicable).
• Right to opt out of profiling that produces legal or similarly significant effects (where applicable).
• Right to non-discrimination for exercising your privacy rights.
• Right to appeal: If we decline to act on your request, you may appeal our decision by emailing office@7g.app.

To exercise these rights, submit a verifiable request via office@7g.app. We will verify your identity before responding and will respond within the time required by applicable law (typically 45 days, extendable where permitted). You may designate an authorized agent to make a request on your behalf with appropriate proof of authorization.

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 (California “Sale” and “Share”)

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 Section 5 (Cookies and Similar Tracking Technologies) for details.

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.