eSimphony, Inc., a Delaware corporation, of 12515 SE 74th St, Newcastle, WA 98056, United States, is the controller of the personal data described here.
Contact for privacy matters and rights requests: support@esimphony.global
Our affiliated company in Vietnam provides engineering, operations and billing support on our instructions. See section 5.
| Account | Email address, display name (optional), credentials, language and communication preferences |
|---|---|
| Orders | Plans bought, destinations, travel dates, expected usage, order history, Balance, conversions of unused data |
| Support | Messages you send to us and to Moza |
| Device and eSIM | Device model, operating system, app version, EID, ICCID, IMSI, MSISDN where assigned, profile status |
| Technical | IP address, crash reports, diagnostic logs |
| Network usage | Data volume, session times and duration, the network and country you are connected to, charging and billing records, connection quality |
| Location | Network-derived location (the country and network serving you) is inherent to providing roaming and charging correctly. Device location is optional and used only with your consent, to suggest plans |
| Payment | Confirmation of payment, card brand, last four digits, country of issue, payment reference. We never receive or store full card numbers |
We do not inspect the content of your communications. We do not read, log or analyse what you send or receive over the connection.
We do not require identity documents, and no destination we currently offer imposes a subscriber registration requirement.
We use cookies and similar technologies. Non-essential ones are used only with your consent, which you can change at any time.
| Purpose | Legal basis |
|---|---|
| Creating and running your account | Contract — Art. 6(1)(b) |
| Configuring, provisioning and delivering eSIM profiles | Contract — Art. 6(1)(b) |
| Providing connectivity and routing your traffic | Contract — Art. 6(1)(b); traffic and location data also governed by the ePrivacy Directive |
| Rating, charging, billing, and running your Balance | Contract — Art. 6(1)(b) |
| Automated plan configuration and pricing by Moza | Contract — Art. 6(1)(b) — see section 4 |
| Customer support, including by Moza | Contract — Art. 6(1)(b) |
| Usage and plan expiry notifications | Contract — Art. 6(1)(b) |
| Fraud prevention, abuse detection, network security | Legitimate interests — Art. 6(1)(f) |
| Enforcing fair use under the Terms | Contract — Art. 6(1)(b) and legitimate interests — Art. 6(1)(f) |
| Product analytics and error monitoring | Legitimate interests — Art. 6(1)(f); consent where it relies on cookies or device identifiers |
| Marketing emails | Consent — Art. 6(1)(a), withdrawable at any time |
| Accounting, tax, and responding to lawful requests from authorities | Legal obligation — Art. 6(1)(c) |
Traffic data is erased or anonymised once it is no longer needed for transmission or billing. Location data other than traffic data is used only where anonymised, where you consented, or where needed for a service you asked for — and you can withdraw that consent at any time, free of charge.
We do not collect data revealing health, religion, political opinions or similar, and ask you not to send such information to Moza.
Moza is an artificial intelligence system, not a person.
Moza configures your plan and quotes a price automatically, from the destination and dates you give it, your expected and previous usage, and our pricing rules, costs and coverage data.
Moza does not score you, assess your creditworthiness, profile your behaviour, or vary your price according to who you are. Two people asking for the same plan get the same price. The result is an offer you may accept or decline.
You can email support@esimphony.global at any time to reach a person, to ask how a price was reached, or to have it reviewed.
Technology. Moza is built on large language models supplied by third parties. Your messages, and the account and order context needed to answer them, are sent to those providers to generate a response. We use these providers on paid service terms under which they are not permitted to use your conversations to train their models, and retain them only briefly for abuse monitoring. Please do not send Moza identity documents, card details, health information or passwords.
| Account data | While your account is open, then 24 months |
|---|---|
| Orders, payments, conversions and Balance | For as long as tax and accounting law requires |
| Traffic and charging records | For as long as needed to bill you and for the period during which a bill may lawfully be challenged or payment pursued, then aggregated into anonymised statistics |
| Network-derived location | As for traffic data |
| Support conversations, including with Moza | 6 months |
| Security, audit and error logs | 6 months |
| Marketing objections | Indefinitely, as a suppression record |
| Aggregated, anonymised statistics | Indefinitely — no longer personal data |
Encryption in transit and at rest; role-based access control and least privilege; multi-factor authentication for administrative access; logged access to production data; vulnerability management and periodic security testing; staff privacy and security training; a documented incident response process.
If a breach is likely to put your rights at high risk, we will tell you without undue delay and explain what happened and what you can do.
Wherever you are, you can ask us for a copy of your data, ask us to correct it, or ask us to delete your account. In the EU, EEA and UK you have the rights to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), and to object to processing based on legitimate interests (Art. 21). You can object to direct marketing at any time, absolutely, and we will stop. You can withdraw consent at any time, without affecting processing already carried out. You can ask for human involvement in, and contest, an automated outcome (Art. 22) — see section 4.
To exercise them: email support@esimphony.global. We respond within one month, extendable by two further months for complex requests, and will tell you within the first month if we need longer. There is no charge unless a request is manifestly unfounded or excessive. We may need to verify your identity first.
Complaints. You can complain to the data protection authority where you live or work, or where the problem occurred. We would appreciate the chance to resolve it first.
The Service is not aimed at children. Anyone under 18 may use it only with the consent of a parent or guardian, who accepts the Terms on their behalf and is responsible for the account. We do not knowingly collect personal data from a child without that consent. If you believe a child has given us their data without it, contact support@esimphony.global and we will delete it.
If you are a California resident, the CCPA as amended gives you the rights to know, delete, correct, opt out of sale or sharing, and limit the use of sensitive personal information, and not to be treated differently for exercising them.
We collect the categories in section 2 — identifiers, commercial information, internet and network activity, and geolocation — from you, your device and the networks you connect to, for the purposes in section 3, and disclose them to the recipients in section 5. We do not collect government identifiers or sensitive personal information, and we do not sell or share personal information as the CCPA defines those terms. Our analytics and error-monitoring providers act as service providers under written contract and may not use your data for their own purposes or for cross-context behavioural advertising.
To exercise your rights, email support@esimphony.global. You may use an authorised agent.
Our affiliated company in Vietnam processes personal data on our instructions and in accordance with Decree 13/2023/ND-CP on Personal Data Protection.
We publish every version with a number and effective date; superseded versions stay available at https://esimphony.global/privacy-policy/{version}. Where a change is material we will tell you by email or in the app before it takes effect. Where it requires your consent we will ask for it.
support@esimphony.global · eSimphony, Inc., 12515 SE 74th St, Newcastle, WA 98056, United States