Privacy Policy
1. Introduction
This Privacy Policy (hereinafter, « Policy ») is intended to inform you about how your personal data is processed by Linkesim Limited (hereinafter, « Linkesim », « We », or « Our ») and specifies the information (including the personal information specified below) related to you or that you provide to us (hereinafter, « Personal Data ») that will be collected and processed by Linkesim and/or a third-party service provider when you contact us through any channel, such as our website, or when you subscribe to our services. We are legally required to provide this information to you, including information about your rights, in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter, « GDPR »).
2. Linkesim as Data Controller
Under this Policy, the controller of your personal data is Linkesim Limited, located at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R, China. Linkesim is responsible for your personal data.
Linkesim is committed to respecting your fundamental rights related to the protection of your Personal Data, and this policy aims to inform you about how we process such data.
3. Types of personal data we process
– Website Usage and Device Data: When you visit our website:
– Your visits and interactions with our website, including the pages you visit, the date and time of your visits, and your mouse clicks;
– Device data, including your IP address, geolocation, device type and language, browser type, and other relevant information;
– Any website you visit via a link on our website.
Most of this Personal Data is collected through cookies. Please see our Cookie Policy for more information on how our website uses cookies.
– Customer Data: When you purchase an eSIM or an internet Subscription:
– Full name, country of residence, current geolocation, residential address, internet service provider, phone number, payment information, email address, device type (brand and model), copy of passport, driver’s licence, or other identification document (if required) and other details you provide when interacting with us to purchase an eSIM.
4. Source of your personal data
During any contractual engagement period between you and us and when you visit our website or app, we collect your personal data: (1) directly provided by you, or (2) indirectly provided by third parties (for example, if you subscribed to our services through affiliated parties or travel agencies).
When you browse our website, various cookies and other tracking systems may be installed on your device, in accordance with our available Cookie Policy. If we wish to collect your personal data through the use of non-essential cookies on our website, your consent will be requested.
5. For what purpose and on what legal basis do we process your personal data?
The key context (hereinafter, « Legal Basis ») under which we process your Personal Data is specified below. This also details how (hereinafter, « Nature of Processing ») and why (hereinafter, « Purposes ») we collect this personal data.
– Compliance with a Legal Obligation (Customer Data): Linkesim may collect your Personal Data as required to comply with legal obligations under applicable laws and regulations, including, but not limited to, the protection and compliance with law enforcement requests.
– Contractual Performance (Customer and Website Data): To enable you to access and use our website; to process eSIM or internet subscription purchases available on our website and for payment processing of such purchases; to calculate and bill for the services we provide; to handle incidents, complaints, or requests regarding our products or services; for post-sale service; and for your registration on our website and/or app, as well as your access to the Linkesim user area.
– Legitimate Interest (Customer and Website Data): To facilitate the use of your eSIM card or internet subscription, including user account management, and to provide customer service; to understand how users use our website to improve it; to tailor our services and products to your needs and, if you consent to advertising, to better target our marketing communications to your preferences; to monitor and prevent cybersecurity risks and fraudulent use of our information, systems, and/or equipment; to enhance our business practices through the use of external platforms; to conduct internal investigations and contact a consumer in case of fraud or identity theft or if there is a serious suspicion of fraud or identity theft; to record calls for training and improvement; to allow for the periodic evaluation of our services and implement customer satisfaction surveys to improve our services; and for activities supporting the smooth conduct of our business, including system testing, network monitoring, employee training, and quality control.
6. Who is your personal data shared with?
Depending on the Purpose for which we collect your Personal Data, these data may be shared with some or all of the following recipients, if necessary:
– Internal Linkesim entities: Linkesim’s internal departments and services (such as customer relations, advertising, or IT services).
– Telecommunication service providers: Service providers in the relevant jurisdiction where the eSIM card was purchased.
– Regulatory authorities and law enforcement: In cases where we are required to disclose or share your Personal Data to comply with judicial or regulatory requests, such as those issued by Revenue Commissioners, the Department of Social Protection, the Data Protection Commission, the Workplace Relations Commission, Irish courts, An Garda Síochána, or other relevant authorities.
– Third-party professionals and consultants: Legal advisers and professional consultants providing specific services to us.
– Third-party service providers: We use third-party service providers who may process your Personal Data on our behalf to fulfil some of the above purposes. These include:
– Administrative services, communication and advertising services, corporate social responsibility services, maintenance services, security services, archiving, storage, and digitisation services, document removal and destruction services, back-office support services, and IT services.
7. International data transfers
Users residing within the European Union are informed that their Personal Data may be transferred to recipients (mainly external service providers) outside the European Economic Area (hereinafter, « EEA ») to countries whose laws and practices do not include equivalent Personal Data protection laws or regulations to those within the EEA (such as Thailand or Colombia). When such transfers occur, we ensure to take all possible precautions by ensuring that: (a) transfers do not occur without our written authorisation, and (b) an appropriate transfer mechanism, such as Module 2 of the Standard Contractual Clauses (as approved by the European Commission) or an adequacy decision by the European Commission, is in place to protect your Personal Data. If you would like to learn more about data transfers related to your Personal Data, please contact us via email: contact@linkesim.com.
8. Your data protection rights
– Right of access: You have the right to access and request a copy of your Personal Data held by Linkesim.
– Right to object: You have the right to object at any time to the processing of your Personal Data when it is processed by Linkesim on the legal basis of legitimate interest.
– Right to rectification: You have the right to have inaccurate Personal Data held by Linkesim updated or corrected.
– Right to erasure: Your Personal Data may be deleted, for example, if you exercise your right to object and Linkesim has no overriding reason to process your Personal Data or if it is no longer necessary for the purposes outlined in this Policy.
– Right to restriction of processing: You have the right to request Linkesim to restrict the processing of your Personal Data in certain cases, particularly if you believe the Personal Data Linkesim holds about you is inaccurate or if its use is unlawful.
– Right to data portability: You have the right to request Linkesim to provide you with all Personal Data held about you in a structured, commonly used, and machine-readable format.
– Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the Member State where your habitual residence, place of work, or where an alleged infringement occurred.
– Right to object to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automated data processing, including profiling, which may have legal or similarly significant effects. We may not be able to fulfil your request if such data processing is necessary to establish or fulfil our contractual obligations or if it is authorised by law.
9. How long do we keep your data?
Generally, we store your Personal Data in compliance with our obligations as determined by Irish and European law and/or for as long as we may need it in connection with our contractual obligations to you, plus a reasonable period. Your Personal Data is retained as long as necessary for the purposes for which we collected it. Criteria used to determine this timeframe include:
– The duration of our contractual obligations plus 7.5 years;
– The possibility that such retention would be deemed prudent for Linkesim’s legal compliance (such as adherence to limitation periods or investigations related to a dispute or regulation);
– The nature of the legal obligations to which Linkesim is subject;
– Six months for login history and call records.
10. Children’s personal data
Linkesim understands the importance of protecting children’s Personal Data, defined as anyone under 18 years of age in France or any other legal age in your jurisdiction.
Linkesim services are prohibited for children (individuals under 18). To our knowledge, we do not collect nor allow any third party to collect the Personal Data of individuals under 18.
If we discover that an individual under 18 has provided us with Personal Data, this data will be promptly deleted, and the user’s account will be terminated.
11. Who to contact if you wish to exercise your privacy rights or have questions regarding your personal data
In accordance with applicable law, Linkesim has a Data Protection Officer. If you have any questions regarding this Policy or wish to exercise your data protection rights, please contact our Data Protection Officer at: contact@linkesim.com.
12. Updates to this policy and other information
We strive to keep this Policy up to date. It is regularly reviewed by us and may be amended or updated from time to time as necessary. Any update to this policy will be published in this section of the website.
This Policy was originally drafted in French. In the event of any conflict between the French version of this Policy and any other translation, the French version shall prevail.
This Privacy Policy was last modified on 1 July 2024.
All rights reserved.
