Privacy Policy for Airalos Digital Roaming

1. Data Controller

Airalos Digital Roaming ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website airalos.click.

For the purpose of data protection laws, the data controller responsible for your personal data is:

• Airalos Digital Roaming
• Address: 27 Rue de Berri, 75008 Paris, France
• Email: [email protected]
• Phone: +33 1 42 68 5301

We are dedicated to ensuring the privacy and security of your personal information in compliance with applicable data protection regulations. Should you have any questions or concerns regarding this policy, please do not hesitate to contact us using the details provided above.

2. Data Collected

At Airalos Digital Roaming, we believe in collecting only the data necessary to provide our services and interact with you effectively. We do not collect extensive personal data or engage in behavioral tracking. The primary situations in which we collect personal data are when you choose to communicate with us through our website's contact form.

Information You Provide Voluntarily:

When you use the contact form on airalos.click to get in touch with us, you may provide the following personal data:

• Name: To address you personally in our response.
• Email Address: To allow us to reply to your inquiry.
• Message Content: Any information you choose to include in your message, which may contain personal details relevant to your query.

Automatically Collected Information:

We want to be clear: Airalos Digital Roaming does not employ third-party analytics services, advertising pixels, or tracking cookies that collect information about your browsing behavior or IP address for marketing or analytical purposes. Our website is designed to be straightforward and respect your privacy. The only automatic collection relates to essential technical data required for the website to function, such as temporary session information, which does not identify you personally.

We do not collect information about your device type, operating system, browser type, referring URLs, or pages viewed, beyond what is minimally necessary for the technical operation of the website. Our focus is on providing useful content about eSIMs, not on gathering extensive user data.

3. Cookies and Local Storage

Our approach to cookies and local storage on airalos.click is minimalistic and privacy-focused. We understand the concerns users have regarding online tracking, and we have built our site to avoid such practices.

The only instance where our website utilizes local storage is to manage your cookie consent preference. When you acknowledge our cookie banner, a small piece of information is stored locally in your browser. This "cookie consent" entry serves one purpose: to remember that you have seen and accepted our cookie policy, preventing the banner from reappearing on every page load during the same browsing session. This local storage item does not contain any personal identifying information, nor does it track your activities across our website or other sites. It merely ensures a smoother user experience regarding policy acknowledgment.

We do not use any other cookies or local storage for:

• Tracking your browsing habits or history.
• Analytics or website performance monitoring.
• Personalized advertising or retargeting.
• Collecting information about your device or location.
• Storing user preferences beyond the cookie consent.

Our commitment is to provide a clean, secure, and privacy-respecting environment for visitors interested in learning about eSIMs for international travel. You can find more information about our general approach to data security on our Policies page.

4. Legal Basis for Processing

Under European data protection laws, including the General Data Protection Regulation (GDPR), we must have a valid legal basis to process your personal data. For the limited data we collect at Airalos Digital Roaming, our legal basis is primarily Consent.

• Consent: When you voluntarily submit information through our contact form, you are providing your explicit consent for us to process that data (your name, email, and message content) for the purpose of responding to your inquiry. We will not use this data for any other purpose without obtaining further consent from you. You have the right to withdraw your consent at any time by contacting us at [email protected].
• Legitimate Interests: In very rare cases, we might process minimal technical data (e.g., temporary session IDs) based on our legitimate interest in ensuring the secure and efficient operation of our website. This processing is always balanced against your rights and freedoms and is non-intrusive.

We ensure that any processing of your personal data is conducted fairly, lawfully, and transparently, always with your rights and interests as a priority. This approach underpins our commitment to transparency.

5. Data Sharing and Disclosure

At Airalos Digital Roaming, we take your privacy seriously. We want to assure you that we do not sell, trade, or otherwise transfer your personal data to third parties for their marketing or any other purposes.

The limited personal data collected via our contact form (name, email, message) is used solely by Airalos Digital Roaming personnel to respond to your inquiries. We do not engage with third-party service providers for analytics, advertising, or data processing that would require sharing your personal contact information.

Exceptions to Disclosure:

We may disclose your personal data only in the following limited circumstances:

• Legal Requirements: If required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Protection of Rights: To protect the rights, property, or safety of Airalos Digital Roaming, our users, or others, including enforcing our Terms and Conditions.

In such instances, we will ensure that any disclosure is strictly limited to what is legally mandated and that your privacy rights are protected to the maximum extent possible. We are dedicated to maintaining the confidentiality of your information.

6. Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Contact Form Inquiries: Information submitted through our contact form (name, email, message content) will be retained for a maximum period of 12 months from the date of your last interaction with us concerning that inquiry. This allows us to refer back to previous communications if a follow-up is needed or if your query is complex. After this period, the data will be securely deleted or anonymized.
• Cookie Consent: The local storage item related to your cookie consent preference is typically retained for a shorter duration, or until you clear your browser's local storage/cookies. It is non-personal and only serves to remember your preference.

In some circumstances, you can ask us to delete your data sooner. Please refer to Section 7 ("Your Rights") for more information on how to exercise your right to erasure. Our commitment to data minimization extends to our retention policies, ensuring we do not hold your data longer than it serves its intended purpose or is legally required.

7. Your Data Protection Rights

Under applicable data protection laws, particularly the GDPR, you have several important rights regarding your personal data. Airalos Digital Roaming is committed to upholding these rights.

• The Right to Access (Article 15 GDPR): You have the right to request copies of your personal data that we hold. We may charge you a small fee for this service if the request is manifestly unfounded or excessive.
• The Right to Rectification (Article 16 GDPR): You have the right to request that Airalos Digital Roaming correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
• The Right to Erasure (Article 17 GDPR): You have the right to request that Airalos Digital Roaming erase your personal data, under certain conditions (e.g., the data is no longer necessary for the purposes for which it was collected, or you withdraw consent).
• The Right to Restrict Processing (Article 18 GDPR): You have the right to request that Airalos Digital Roaming restrict the processing of your personal data, under certain conditions (e.g., if you contest the accuracy of the data, for a period enabling us to verify the accuracy).
• The Right to Data Portability (Article 20 GDPR): You have the right to request that Airalos Digital Roaming transfer the data that we have collected to another organization, or directly to you, under certain conditions, where technically feasible.
• The Right to Object to Processing (Article 21 GDPR): You have the right to object to Airalos Digital Roaming’s processing of your personal data, under certain conditions (e.g., where processing is based on legitimate interests and there are no compelling legitimate grounds for the processing).
• The Right to Withdraw Consent (Article 7(3) GDPR): If our processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at [email protected] or write to us at the address provided in Section 1. We will respond to your request within one month. We may need to verify your identity before fulfilling your request to ensure the security of your data.

8. Right to Complain to a Supervisory Authority

While we hope to resolve any questions or concerns you have about our data handling practices directly, you have the right to lodge a complaint with a supervisory authority. This right applies if you believe that Airalos Digital Roaming has processed your personal data in a way that infringes applicable data protection laws.

For residents within the European Union, the supervisory authority in France, where Airalos Digital Roaming is based, is the Commission Nationale de l'Informatique et des Libertés (CNIL).

• Commission Nationale de l'Informatique et des Libertés (CNIL)
• Website: www.cnil.fr
• Address: 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, France

We encourage you to contact us first at [email protected] so we can attempt to resolve any issue you may have. However, your right to complain to the supervisory authority is unaffected.

9. Changes to This Privacy Policy

Airalos Digital Roaming reserves the right to update or change our Privacy Policy at any time. We will post any changes on this page with an updated "Last Updated" date at the top of the policy. We encourage you to review this Privacy Policy periodically for any modifications.

Significant changes that materially alter how we process your personal data will be communicated more prominently, for example, by placing a notice on our website homepage or by directly contacting you if we hold your contact information and it is appropriate to do so. Your continued use of the website after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

10. Contact Us

If you have any questions or concerns about this Privacy Policy, our data practices, or your rights under this policy, please do not hesitate to contact us. We are here to help demystify how your data is handled and provide clarity.

• Email: [email protected]
• Phone: +33 1 42 68 5301
• Address: Airalos Digital Roaming, 27 Rue de Berri, 75008 Paris, France

We are committed to responding to all inquiries promptly and comprehensively. Your privacy is a cornerstone of our service at Airalos Digital Roaming.