Privacy Policy

Introduction

This document (hereinafter referred to as the "Privacy Policy") describes the privacy rules for all information collected or submitted when users access, install, or use roaming2 services, web applications, and websites, regardless of the device used (computer, phone, tablet, etc.).

In this Privacy Policy, "Personal Data" means any information or set of information that allows us to identify a user directly or indirectly (such as name, surname, email address, phone number, etc.).

Users should read this Privacy Policy together with the Terms of Service.

By registering an account, accessing and using the website, ordering and/or using data plans, logging in via a third-party account, or contacting us regarding roaming2 matters (collectively the "Services"), users confirm they have read and agree to be bound by this Privacy Policy.

1. Processing and Collection of Personal Data

To provide our services and operate our website, we need to process certain information that can identify you. The specific types of data we collect depend on how you interact with our services and applicable legal requirements.

Information Required for Account Creation and Service Registration

• Name, Email Address: We collect the user's full name and email address during registration.
• Third-Party Login (OAuth) Data: When you choose to log in using a third-party social account such as Facebook, LINE, Google, or Apple, we receive your public profile information from that platform.
• Order Data: When a user orders services, we process specific order information (such as data plan, duration, currency, status, etc.).

Payment-Related Information

• Basic Billing Data and Tokenization: Your payment information is processed by trusted third-party payment providers (such as Stripe and PayPal). We do not store your full credit card number on our servers.
• Country/Region and Geolocation (Cloudflare IP): We integrate third-party geolocation services to detect your country or region via your IP address.
• Refunds and Dispute Resolution: We may process transaction details to verify legitimacy.

Communications and Website Usage Data

• Communications Data: We use your email to send order receipts, eSIM guides, and, with your consent, marketing offers.
• Access Logs and Cookies: We collect IP addresses, browser types, device types, and pages visited.

2. Legal Basis for Processing

We process your personal data based on the following legal grounds: (a) performance of a contract; (b) your consent; (c) compliance with legal obligations; (d) legitimate interests.

3. Sharing of Personal Data

We do not share or sell users' personal data to third parties except in the following circumstances:

• Service Providers: Google Analytics, Stripe, PayPal, etc.
• Protection of Rights: To comply with law enforcement or court orders.
• Business Transfer: In the event of a merger, acquisition, or asset sale.
• Cross-Border Transfer: Data may be processed in Hong Kong or where service providers are located.

4. User Data Choices and Rights

You may have the right to access, correct, or delete your personal data, or to withdraw consent.

5. Data Security

We use SSL/TLS encryption for data in transit. However, no company can guarantee absolute security of internet communications.

6. Data Retention and Deletion

• Account data: retained for 3 years from last activity.
• Billing information: retained for 10 years (to comply with Hong Kong regulations).
• When no longer needed, data will be securely destroyed or anonymized.

7. Country/Region-Specific Provisions

• EEA Users: Enjoy rights under the GDPR.
• California Users: Enjoy rights under the CCPA. We do not sell your personal information.
• Other: Please contact us to exercise applicable local rights.

8. Children's Data

We do not knowingly collect any data from individuals under 18. If discovered, we will delete it immediately.

9. Other Terms

• Limitation of Liability: Users are responsible for account password security.
• Third-Party Links: We are not responsible for the practices of third-party websites.
• Policy Updates: Material changes will be notified. Continued use constitutes acceptance.