Privacy policy

This document can be printed for reference.

Welcome to Orbit Mobile! We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application with eSIM functionality. Orbit Mobile collects some Personal Data from its Users through their use of this application.

This Privacy Policy (The “Policy”) applies to the application and Website (The “Platform”) - if not stated otherwise within this document - owned and operated by ORBIT MOBILE LIMITED (The “Company”), a company duly incorporated and registered under number 15769083 and established at the following address: Irongate House, 30 Dukes Place, London EC3A 7LP, in its capacity of owner and controller of the personal data.

By registering an account, using or visiting the Platform, viewing any product, software, tool, data feed, and/or service, or by submitting personal data to the Company (collectively the “Service”), you understand and agree to the terms of this Policy and you consent to the Company’s use of your personal data in the manner set out in this Policy. Users are advised to review Orbit Mobile’s Terms and Conditions and Cookies Policy before using the Platform.

1. Construction

In this Privacy Policy, the terms set out below shall (unless the context requires otherwise) have the following respective meanings:

• Personal Data (or Data): means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
• Usage Data: means information collected automatically through this App/Website (or third-party services employed), which can include: the IP addresses or domain names of the computers utilized by the Users who use this App/Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
• Cookie: means Trackers consisting of small sets of data stored in the User's browser. It is used to identify the User’s browser, provide analytics, remember information about the User such as its language preference or login information.
• Data Controller (or Owner): means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. The Data Controller, unless otherwise specified, is the Owner of this Application/Website.
• Data Processor (or Data Supervisor): means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
• Data Subject: means the natural person to whom the Personal Data refers.
• Legal information: means this privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
• Service: means the service provided by this Application/Website as described in the relative terms (if available) and on this site/application.
• Tracker: means tracker indicates any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
• User: means the individual using this Application/Website who, unless otherwise specified, coincides with the Data Subject.
• Website (or Application): means the means by which the Personal Data of the User is collected and processed.

Other defined terms shall have the meaning set out in the Section in which that term is first used.

2. Information We Collect

2.1 Personally-Identifiable Information

We may collect personal information such as your name, email address, phone number, and eSIM profile information necessary for providing eSIM functionality. This also includes billing information such as credit card number and billing address when you sign up for the newsletter, create an account, or make purchases.

Your data is collected and processed to:

• Administer your account.
• Process your orders and verify financial transactions.
• Provide customer service and respond to inquiries.
• Conduct direct marketing, research, and analysis.
• Send you information about our products and services, provided you have not opted out of such communications.

2.2 Usage Data

We may automatically collect certain data when you use our Application/Website, such as your device identifier, IP address, browser type, and operating system. This includes log information such as time and date of visit, viewed pages, and URL of the site that referred you to our Application/Website.

2.3 Location Information

With your consent, we may collect precise geolocation information from your mobile device when the app is running in the foreground or background.

2.4 Sensitive Personal Data

We request that you do not send or disclose any sensitive personal data (e.g., social security numbers, health information) on or through the services or otherwise to the Company. If you do submit such data, you consent to its processing in accordance with this Policy.

3. Cookies and Similar Technologies

3.1 Cookies

The Company and its partners use cookies or similar technologies to analyze trends, administer the Application/Website, track users’ movements around the Application/Website, and gather demographic information. Cookies are small data files stored on your computer or mobile device by a website.

3.2 Types of Cookies

• Strictly Necessary Cookies: Essential for providing services and enabling features you request.
• Functionality Cookies: Remember your preferences and enhance your experience.
• Performance Cookies: Collect information about traffic and usage to improve services.
• Targeting Cookies: Deliver adverts relevant to your interests and measure ad campaign effectiveness.

3.3 Pixels and Local Storage

We may use pixel tags (web beacons and clear GIFs) to track user actions on the Application/Website. Pixel tags measure the success of marketing campaigns and compile statistics about usage.

4. How We Use Your Information

We use the information we collect in the following ways:

• To provide and maintain our app's functionality, including eSIM management and related services.
• To personalize your experience and improve our app.
• To respond to your inquiries, provide customer support, and communicate with you.
• To detect, prevent, and address technical issues and security vulnerabilities.

Mode and Place of Processing the Data

1. Methods of processing

• The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
• The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application/Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

2. Legal basis of processing

• The owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal and/or regulatory obligation to which the Owner is subject; or
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
• In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

3. Place

• The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
• Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
• If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

4. Retention time

• Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
• Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

5. The purposes of processing

• The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal and/or regulatory obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Hosting and backend infrastructure, Traffic optimization and distribution, Analytics, managing contacts and sending messages, SPAM protection and Infrastructure monitoring.
• For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
• Detailed information on the processing of Personal Data.

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application/Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application/Website.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Infrastructure monitoring

This type of service allows the Owner to monitor the use and behaviour of this Application/Website’s components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application/Website.

SPAM protection

This type of service analyses the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Traffic optimization and distribution

This type of service allows the Owner to distribute the content of this Application/Website using servers located across different countries and to optimize performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between the Owner and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.

Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Users have the right to bring a claim before their competent data protection authority.

Details about the Right to Object to Processing

• Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
• Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
• Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

• The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application/Website or the related Services.
• The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application/Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

USER RIGHTS AND DATA DELETION

Users have the right to request access to the personal data the Company holds about them. Requests for data access can be made by contacting the Company at privacy@orbitmobile.com. The Company will provide the requested information in accordance with applicable data protection regulations, including the General Data Protection Regulation (GDPR).

Data Deletion

Users may request the deletion of their personal data by contacting privacy@orbitmobile.com. Data will be deleted unless retention is required to comply with legal obligations, resolve disputes, or enforce agreements.

Policy Updates

The Company reserves the right to update its data protection practices and will notify Users of any significant changes to this policy.

System Logs and Maintenance

For operation and maintenance purposes, the Owner and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information Not Contained in this Policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Children's Privacy

Our app is not intended for children under the age of 13. We do not knowingly collect or solicit personal information from children under 13.

Changes to this Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application/Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Kingdom.