1. Who we are and what this policy covers
1.1. This Privacy Policy explains how Tellavant Connect Ltd collects, uses, shares and protects your personal data when you use the website simtoken.cc and the services offered through it (the Service).
1.2. The Service is an online store of eSIM data plans for mobile internet abroad. You top up your account balance in Tokens (TKN), choose a data plan for a country, a region or global coverage, and receive an eSIM profile as a QR code, manual installation details and installation instructions.
1.3. The controller of your personal data is Tellavant Connect Ltd, a company registered in England and Wales under company number 17539371, with its registered office at 79 College Road, Harrow, HA1 1BD, United Kingdom (we, us, our).
1.4. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR). Where the EU General Data Protection Regulation (EU GDPR) applies to our processing, we also comply with it.
1.5. For any question about this policy or your personal data, contact us at support@simtoken.cc.
1.6. The Service is intended only for persons aged 18 and over. By registering, you confirm that you are at least 18 years old.
1.7. This policy should be read together with our Terms & Conditions. Terms with capital letters that are not defined here have the meaning given in the Terms & Conditions.
2. Personal data we collect
2.1. Account data. When you register, we collect your name, email address and password (stored only in protected, non-readable form), together with a record of your consent to the Terms & Conditions and this Privacy Policy and the date and time it was given. We verify your email address before the account is activated.
2.2. Third-party sign-in data. If you register or sign in with your Google account, we receive from Google your name, email address and a unique account identifier, and, if available, your profile picture. We do not receive your Google password. The data Google shares is determined by your Google account settings and Google's own privacy policy.
2.3. Balance and transaction data. We keep a record of your Token balance, each top-up (date, amount in EUR and the Tokens credited), each data plan purchase, Tokens returned to your balance, and requests to withdraw an unused balance.
2.4. Billing details. When you top up your balance, we collect the billing details needed for the payment, such as your name, billing address and country, and the payment amount. We do not collect or store your full payment card number, expiry date or security code (see section 4).
2.5. eSIM and plan data. For each data plan, we process the plan purchased (country, region or global coverage, data volume and validity period), the identifiers of the eSIM profile issued to you (such as the ICCID and activation code), the dates of issue, installation and activation, the data volume used and remaining, and the network country in which the plan is used, as reported by our connectivity partners.
2.6. Device data. To check that your device can use an eSIM, we may process your device model and whether it supports eSIM. We do not access the contents of your device.
2.7. Support data. When you contact us, we process your messages, the information you provide (for example, screenshots, device details or a description of a connection problem) and our replies. To protect your account, we may ask you to confirm your identity before we act on a request.
2.8. Technical and usage data. When you use the Service, we automatically collect IP address, browser type and version, operating system, language settings, approximate location derived from the IP address, pages viewed, date and time of access, and log data related to security events, such as sign-in attempts.
2.9. Cookie data. We collect data through cookies and similar technologies as described in section 11.
2.10. We do not intentionally collect special categories of personal data (such as health data, religious beliefs or political opinions). Please do not send us such data when contacting support.
2.11. The tariffs are data-only: we do not provide voice calls, SMS or a phone number, so we do not process the content of calls or messages. We do not see the websites you visit or the content you transmit through the mobile data connection.
2.12. Providing account and billing data is necessary to enter into and perform our contract with you. Without it, we cannot open an account, credit your balance or issue an eSIM profile.
3. How we use your personal data and our lawful bases
3.1. We use your personal data only for the purposes below and only where we have a lawful basis under Article 6 of the UK GDPR.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Creating and managing your account, verifying your email address, enabling sign-in | Account data, third-party sign-in data, technical data | Performance of a contract |
| Topping up your balance, crediting Tokens, keeping your Token balance and transaction history | Balance and transaction data, billing details | Performance of a contract |
| Selling data plans, issuing eSIM profiles, providing the QR code, manual installation details and instructions | Account data, eSIM and plan data, device data | Performance of a contract |
| Delivering connectivity, tracking data volume and validity, stopping data transfer when the volume is used up | eSIM and plan data | Performance of a contract |
| Handling support requests, returning Tokens to your balance where a profile was not issued or a plan did not work in the stated country, processing balance withdrawals, refunds and withdrawals from the contract | Support data, eSIM and plan data, balance and transaction data | Performance of a contract; legal obligation (consumer law) |
| Handling requests to access, export, correct or delete personal data | Account data, support data | Legal obligation |
| Sending service messages about your account, purchases, plans and changes to our terms | Account data, eSIM and plan data | Performance of a contract; legitimate interests (keeping you informed) |
| Preventing fraud and abuse, enforcing the ban on resale and transfer of eSIM profiles, blocking accounts that break our rules, keeping the Service secure | Account data, transaction data, eSIM and plan data, technical data | Legitimate interests (protecting our business, users and partners) |
| Keeping accounting and tax records | Balance and transaction data, billing details | Legal obligation |
| Establishing, exercising or defending legal claims | Any relevant data | Legitimate interests |
| Analysing use of the Service to improve it | Technical and usage data, cookie data | Consent (for non-essential cookies); legitimate interests (aggregated statistics) |
| Sending marketing emails about our offers | Name, email address | Consent, or legitimate interests for similar services where you are an existing customer (PECR soft opt-in) |
3.2. Where we rely on legitimate interests, we have balanced them against your rights and freedoms. You can ask us for more information about this assessment through support.
3.3. Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before it. You can unsubscribe from marketing emails using the link in each email or by writing to support.
3.4. We do not make decisions that produce legal or similarly significant effects for you based solely on automated processing, including profiling. Decisions to block an account are reviewed by our team.
3.5. We do not sell your personal data.
4. Payments
4.1. Data plans are paid for only from your internal Token balance. You top up the balance through our payment partner, an authorised payment service provider. The exchange rate is 1 EUR = 10 TKN. Prices include applicable taxes and are the same in all countries.
4.2. For each top-up, we pass to our payment partner only your billing details and the payment amount.
4.3. The payment page, entry and processing of your card details, 3-D Secure authentication, payment checks and refunds to your card are handled by our payment partner. Our payment partner acts as an independent controller of the data it collects and processes it under its own privacy notice, which is shown to you on the payment page.
4.4. We do not receive or store your full card number, expiry date or security code. From our payment partner we receive only the information needed to credit your balance and keep our records: the payment result, the amount, the date and time, a transaction reference and, where provided, a masked card number (for example, the last four digits) and card type.
4.5. Requests to cancel a payment, return an unused balance or withdraw from the contract are handled only through support at support@simtoken.cc. Refunds of money are made within 14 days from the date of your request.
5. Who we share your personal data with
5.1. We share personal data only to the extent necessary for the purposes in section 3, with the following categories of recipients:
- Payment service provider (our payment partner): billing details and payment amount, to process top-ups and refunds to your card.
- Connectivity partners (eSIM platform providers and mobile network operators): eSIM profile identifiers and plan details, to issue and activate profiles, deliver mobile data and report data usage. We do not pass your name or email address to them unless this is needed to resolve a connection problem you have reported.
- Sign-in provider: if you choose to sign in with your Google account, data is exchanged with Google as described in section 2.2.
- IT and infrastructure providers: hosting, data storage, email delivery, customer support tools, security and anti-fraud services, acting as our processors under written contracts.
- Analytics providers: where you have consented to analytics cookies.
- Professional advisers: lawyers, accountants and auditors, under duties of confidentiality.
- Public authorities, courts and law enforcement: where we are required to do so by law or to establish, exercise or defend legal claims.
- A buyer or successor: if we sell, merge or reorganise our business, in which case the recipient will be bound by this policy or an equivalent one.
5.2. Our processors may use your personal data only on our instructions and must protect it in line with data protection law.
6. International transfers
6.1. Some of our partners and providers are located, or process data, outside the United Kingdom. Because connectivity is provided in the country where you use the plan, eSIM and plan data may be processed by network operators in that country.
6.2. When we transfer personal data outside the UK (or, where the EU GDPR applies, outside the European Economic Area), we make sure it is protected by at least one of the following safeguards:
- the country has been recognised as providing an adequate level of protection (UK adequacy regulations or, for EU data, an adequacy decision of the European Commission);
- we have entered into the International Data Transfer Agreement or the International Data Transfer Addendum to the EU Standard Contractual Clauses issued by the UK Information Commissioner, or, for EU data, the EU Standard Contractual Clauses;
- the transfer is necessary for the performance of our contract with you, for example to deliver connectivity in the country you are travelling to.
6.3. You can ask us for more information about these safeguards through support.
7. How long we keep your personal data
7.1. We keep personal data only for as long as needed for the purposes for which it was collected:
| Data | Retention period |
|---|---|
| Account data | While your account is open, and up to 30 days after it is closed |
| Balance, transaction and billing records | 6 years from the end of the financial year in which the transaction took place (UK accounting and tax law) |
| eSIM and plan data | While the plan is valid, then 2 years from its expiry, to handle questions and claims about the plan |
| Support correspondence | 3 years from the date the request was closed |
| Technical and security logs | Up to 12 months |
| Records of consents and data protection requests | For the duration of the processing and 6 years after |
| Marketing data | Until you withdraw consent or unsubscribe |
7.2. We may keep data longer where required by law or where it is needed to establish, exercise or defend a legal claim. Where data is held only for that reason, we restrict its use accordingly.
7.3. When the retention period ends, we delete or irreversibly anonymise the data.
8. Deleting your account
8.1. You can ask us to delete your account by writing to support@simtoken.cc from the email address linked to the account.
8.2. When your account is deleted, your Token balance is closed. We return any unspent balance within 14 days from the date of your request.
8.3. eSIM profiles already purchased continue to work until the end of their paid validity period. For this reason, we keep the eSIM and plan data needed to deliver connectivity until the period ends.
8.4. After deletion, we keep only the data we must retain under section 7, such as transaction records required by law. All other personal data is deleted or anonymised.
9. Your rights
9.1. Under data protection law, you have the right to:
- access your personal data and receive a copy of it;
- rectification of inaccurate or incomplete data;
- erasure of your data, where there is no longer a lawful reason to keep it;
- restriction of processing, for example while we check the accuracy of your data;
- data portability, that is, to receive the data you provided to us in a structured, commonly used, machine-readable format, or to have it sent to another controller;
- object to processing based on our legitimate interests, and to object at any time to direct marketing;
- withdraw consent at any time, where processing is based on consent.
9.2. All requests to access, export, correct or delete your personal data, and to exercise any other right in this section, are handled only through support at support@simtoken.cc. Please write from the email address linked to your account so that we can confirm your identity.
9.3. We respond within one month of receiving your request. Where a request is complex or we receive several requests from you, we may extend this period by up to two further months and will tell you why. Exercising your rights is free of charge, unless a request is clearly unfounded or excessive.
9.4. Some rights are not absolute. For example, we may refuse to erase data that we must keep by law. If we cannot fully meet your request, we will explain why.
10. Security
10.1. We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration and disclosure. These include encryption of data in transit, protected storage of passwords, access controls limited to staff who need the data for their work, and regular review of our security practices.
10.2. Your eSIM profile QR code and installation details give access to the data plan. Do not share them with anyone: resale and transfer of profiles are prohibited, and a profile can be installed on one device only.
10.3. Keep your password confidential and tell us at once at support@simtoken.cc if you suspect unauthorised access to your account.
10.4. If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours of becoming aware of it, and will inform you without undue delay where the risk is high.
11. Cookies and similar technologies
11.1. We use cookies and similar technologies on simtoken.cc:
- Strictly necessary cookies keep you signed in, protect your account and remember your cookie choices. They do not require consent.
- Analytics cookies help us understand how the Service is used so we can improve it.
- Marketing cookies help us measure the effectiveness of our advertising.
11.2. We place analytics and marketing cookies only with your consent, which you give or refuse when you first visit the site. You can change your choice at any time in the cookie settings on the site or in your browser settings. Blocking strictly necessary cookies may prevent parts of the Service from working.
12. Persons under 18
12.1. The Service is not intended for persons under 18, and we do not knowingly collect their personal data. If we learn that an account belongs to a person under 18, we will close it and delete the related data, subject to section 7. If you believe that a person under 18 has given us personal data, please contact support.
13. Changes to this policy
13.1. We may update this Privacy Policy from time to time. The current version is always available on simtoken.cc, with the date of the last update at the top. We will tell you about material changes by email or through your account before they take effect.
14. Contact us and complaints
14.1. For any question about this policy or the processing of your personal data, write to:
Tellavant Connect Ltd 79 College Road, Harrow, HA1 1BD, United Kingdom Email: support@simtoken.cc
14.2. If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner's Office (ICO), at ico.org.uk or on 0303 123 1113. If you live in the European Economic Area, you may also complain to the data protection authority in your country of residence. We would, however, appreciate the chance to deal with your concerns first, so please contact us before you approach the regulator.