Privacy Policy

Last Updated: 18 July 2024

1. General Information

So Close LLC ("Only eSIM," "we," "us," or "our") values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information ("Personal Data") when you interact with us through our application, website, or services (collectively the "Services"). By using our Services, you agree to the terms of this Privacy Policy.

Data Controller

For the purposes of this Privacy Policy, the data controller is Only eSIM, located at 1401 21st St Ste R, Sacramento, CA 95811. Only eSIM is responsible for your Personal Data and ensuring it is processed in compliance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR").

2. Sources of Personal Information

We collect Personal Data directly from you when you interact with us or our Services, and indirectly from third parties, such as affiliates or travel agencies.

Personal Information We Process

We collect various types of Personal Data depending on your interactions with us:

- Website Usage and Device Data: Information about your visits and interactions with our website, including IP address, location data, device type, browser type, and linked websites accessed through our website. This data is often collected using cookies and similar technologies.

- Customer Data: Information you provide when purchasing an eSIM or data plan, such as your name, email, payment information, and identification documents (e.g., passport, driving license).

3. How We Process Personal Information

We process your Personal Data for various purposes based on the following legal necessities:

- Compliance with Legal Obligations: To comply with legal obligations under EU and applicable laws, including law enforcement requests.

- Performance of a Contract: To provide and manage our Services, including processing payments, handling customer incidents, and performing post-sales services.

- Legitimate Interests: To improve our Services, tailor marketing efforts, prevent fraud, conduct internal reviews, and enhance customer service.

4. Sharing Personal Information

We may share your Personal Data with:

- Regulatory Authorities and Law Enforcement Agencies: To comply with legal obligations such as court orders, subpoenas, warrants, or other legal processes. We may also share your information in order to investigate, take action, or prevent against any illegal activities.

- Telecommunications Service Providers: For providing eSIM services through our network partners in order to meet fulfillment of orders and purchases.

- Service Providers: Third parties that process data on our behalf for administrative, advertising, IT, and other services.

- Third-Party Advisors: Professional advisors like consultants and legal advisors.

- Internal Departments: Such as sales, marketing, and IT.

5. International Data Transfers

Your Personal Data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your data.

6. Your Data Protection Rights

You have various rights regarding your Personal Data, including:

- Access: Request a copy of the Personal Data we hold about you.

- Restriction: Request restriction of processing under certain conditions.

- Rectification: Request correction of inaccurate Personal Data.

- Data Portability: Request your data in a structured, commonly used, and machine-readable format.

- Erasure: Request deletion of your Personal Data under certain conditions.

- Objection: Object to processing based on legitimate interests.

- Complaint: Lodge a complaint with a supervisory authority.

To exercise your rights, contact our customer service team at [email protected].

7. Data Retention

We retain your Personal Data only as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. The retention period varies based on the type of data and the purposes of processing.

8. Children's Personal Data

Our Services are not intended for children under the age of 18. We do not knowingly collect Personal Data from children under 18. If we become aware of such data, we will delete it and the appropriate account promptly.

9. Security

We implement appropriate technical and organizational measures to protect your Personal Data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on our website, and the effective date will be updated accordingly. We encourage you to review this policy periodically.

11. California Privacy Rights (CCPA and CPRA)

If you are a California resident, you have specific rights regarding your Personal Data under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

- Right to Know: You have the right to request that we disclose the categories and specific pieces of Personal Data we have collected about you.

- Right to Delete: You have the right to request that we delete Personal Data we have collected from you, subject to certain exceptions.

- Right to Opt-Out: You have the right to opt-out of the sale of your Personal Data. ** Only eSIM does not sell Personal Data. **

- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

To exercise these rights, please contact us at [email protected].

12. California Online Privacy Protection Act (CalOPPA)

Under CalOPPA, Only eSIM makes the following disclosures:

- Do Not Track Signals: We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

- Third-Party Behavioral Tracking: We do not authorize third-party behavioral tracking.

- CalOPPA Compliance: Users can visit our site anonymously. Our Privacy Policy link includes the word “Privacy” and can be easily found on our homepage or as a minimum, on the first significant page after entering our website.

13. Cookie Policy

We use cookies and similar tracking technologies to collect information about your interactions with our website and Services. Cookies are small data files stored on your device. We use cookies for various purposes, including:

- Necessary Cookies: To enable the basic functionality of our website.

- Performance Cookies: To analyze website usage and improve performance.

- Functional Cookies: To remember your preferences and enhance your experience.

- Targeting Cookies: To deliver relevant advertisements and track ad performance.

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website.

14. Contact Information

If you have any questions or concerns about this Privacy Policy or your data protection rights, please contact our customer service team at [email protected].