### Privacy Policy

Last updated: March 2026

## Summary

We collect only the data needed to deliver our eSIM services, never sell your information to third parties, protect your data with industry-standard security, and respect your privacy rights under applicable U.S. law including the CCPA.

## 1. Information We Collect

We collect information you provide directly to us, such as when you create an account, purchase an eSIM plan, or contact our support team.

- Personal Identifiers: Full name, email address, phone number, and billing address.
- Payment Information: Credit/debit card details processed securely through our PCI-DSS compliant payment processors. We do not store your full card number.
- Device Information: IMEI number, device model, and operating system version to verify eSIM compatibility.
- Usage Data: Data consumption, activation timestamps, plan details, and connection logs for service delivery and troubleshooting.
- Communications: Any messages or emails you send to our support team.

## 2. How We Use Your Information

- Provide, maintain, and improve our eSIM services and related platforms.
- Process transactions and send transactional communications including order confirmations and activation instructions.
- Send promotional communications where you have opted in (you may opt out at any time).
- Monitor and analyze usage patterns to improve service reliability and performance.
- Detect, investigate, and prevent fraudulent transactions and illegal activities.
- Comply with applicable U.S. federal and state laws.
- Respond to customer support requests.

## 3. Information Sharing & Disclosure

We do not sell, trade, or rent your personal information.

- Service Providers: Trusted third-party vendors assisting with payments, infrastructure, and analytics.
- Telecom Partners: Necessary identifiers shared to activate your eSIM.
- Legal Requirements: If required by law or governmental authority.
- Business Transfers: In the event of merger, acquisition, or asset sale.
- With Your Consent: For other purposes with your explicit approval.

## 4. Data Retention

- Account Data: Duration of account + up to 3 years after closure.
- Transaction Records: 7 years for tax and regulatory compliance.
- Usage Logs: 90 days, then anonymized or deleted.
- Marketing Preferences: Until you opt out.

You may request deletion of your personal data at any time, subject to legal retention obligations.

## 5. Cookies & Tracking Technologies

- Essential Cookies: Required for authentication and core functionality.
- Analytics Cookies: Used to understand visitor interactions (aggregated/anonymized).
- Marketing Cookies: Used for advertising and campaign measurement.
- Preference Cookies: Store language and regional settings.

You can manage cookie settings through your browser. Disabling certain cookies may impact functionality.

## 6. Data Security

- All data is encrypted using TLS 1.2 or higher.
- Payments handled by PCI-DSS Level 1 certified processors.
- Role-based access controls within our organization.
- Regular security audits and vulnerability assessments.

In the event of a data breach, we will notify affected users as required by U.S. state laws, including the CCPA.

## 7. Your Rights & Choices

- Right to Know
- Right to Delete
- Right to Correct
- Right to Opt-Out (we do not sell personal data)
- Right to Non-Discrimination
- Marketing Opt-Out

To exercise your rights, contact: privacy@flecible.com or +1 (800) 555-0192.

## 8. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect data from children. If discovered, such information will be deleted promptly.

## 9. Changes to This Policy

- We will update the "Last Updated" date.
- Notify registered users 30 days before material changes take effect.
- Require renewed consent for significant changes where necessary.

Continued use of our services constitutes acceptance of the updated policy.

## 10. Contact Us

Email: privacy@flecible.com

Phone: +1 (800) 555-0192

Mail: Flecible Inc., 101 Market Street, Suite 400, San Francisco, CA 94105, USA

Response Time: Within 30 days.