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Privacy Policy

Last Updated: September 16, 2025

Welcome to KudoSIM. This policy explains how we collect, use, store and share your personal information when you use our eSIM application and services, including the sites kudoesim.com , kudo.travel and related sub-sites.

Short note: The sole data controller is KUDOSIM LLC, 651 N Broad St, Suite 201, New Castle, DE 19709, USA . We comply with the GDPR and applicable privacy regulations.

1) Who we are

If you are an EU/EEA resident or the processing takes place in the EU, the legal basis and your rights apply under the GDPR.

2) What data do we collect?

We only collect the data we need to provide the service:

a) Account details

  • First name, last name, email, phone number.

  • Login credentials (hashed), user ID.

b) Order details & eSIM

  • Packages purchased, country/region of coverage, activation dates.

  • EID/ICCID , QR, configuration instructions.

  • Usage status (e.g., GB remaining – for your display only).

c) Payments

  • We use payment providers (e.g. Stripe, Apple Pay, Google Pay). We do not store full card details; they are processed by our providers. We store transaction references and payment status.

d) Equipment & diagnostics

  • Device model, OS/SDK, IP, device identifier, error logs, performance.

  • Similar cookies/identifiers for functionality and analytics.

e) Communications & support

  • Your live chat/WhatsApp/email messages, support tickets, complaints, proof of transactions.

f) Analytics & consent marketing

  • Site/app interactions, referrers, campaigns; only when you have consented to optional cookies.


 

3) Why we process it (purposes & legal bases)

  • We offer eSIM service & contract fulfillment (GDPR Art. 6(1)(b)).

  • Payment & abuse prevention (legitimate interest / legal obligation).

  • Customer support & communications (contract/legitimate interest).

  • Product improvement & analytics (legitimate interest or consent, depending).

  • Marketing (only with your consent ; can be withdrawn at any time).


 

4) Who do we share data with?

We share data only as necessary with:

  • Payment providers : Stripe, Apple/Google Pay.

  • Network operators & eSIM partners : for technical activation of eSIM.

  • Cloud hosting & infrastructure : for secure storage and execution.

  • Analytics & marketing : only with consent (e.g., anonymous analytics).

  • Support & communication : live chat/email/WhatsApp platform.

  • Legal authorities : when required by law or to protect our/your rights.

All processors are bound by data processing agreements (DPA) and comply with security standards.


 

5) International data transfer

Data may be stored or processed in locations outside of your place of residence. Where required by the GDPR, we use standard contractual clauses (SCCs) or other valid mechanisms for transfers.

6) How long do we keep data (retention)

  • Account data: as long as the account is active.

  • Order/billing data: 5–10 years according to fiscal requirements.

  • Technical/diagnostic logs: typically 90–365 days , unless longer is required for security/error resolution.

  • Consent-based marketing: until you withdraw consent or the purpose expires.

When we no longer need them, we anonymize them or securely delete them.


 

7) Security

We use industry practices: encryption in transit & at rest (when applicable), role-based access controls, auditing, backups, periodic testing, and privacy/security training for staff.

8) Your rights

Depending on your jurisdiction, you may have the following rights:

  • Access to your data; copies of them.

  • Correction of incorrect data.

  • Erasure (“right to be forgotten”).

  • Restriction of processing.

  • Data portability .

  • Objection to processing based on legitimate interest/marketing.

  • Withdrawal of consent when processing is based on consent.

To exercise it, write to us at support@kudoesim.com , live chat or WhatsApp (text). We will respond to you within the legal deadlines.

9) Cookies & similar technologies

  • Essentials : functionality, security, payment.

  • Analytics/performance : with consent, for improvement.

  • Marketing : with consent only.
    You can manage your preferences through the cookie banner and browser settings.

10) Children

The Service is not directed at anyone under the age of 16 (or the minimum age under local law). We do not knowingly collect data from children; if you believe we have collected it, please contact us for deletion.


 

11) Communications

  • Transactional notifications : purchase confirmations, activations, usage warnings – necessary.

  • Marketing : with consent; you can unsubscribe at any time (link in email/option in app).

12) Complaints

If you believe that your rights have been violated, you can complain to your national data protection authority. However, we ask that you contact us first so that we can resolve the matter together.

13) Changes to this policy

We may update it from time to time. When there are material changes, we will notify you on the app/site or by email. The “Last Updated” date indicates the most recent version.

14) How to contact us