Privacy Policy

1. General Provisions

This Privacy Policy explains how TELECODE SOLUTIONS LTD, operating the Flashsim service (“Flashsim”, “we”, “us” or “our”), collects, uses, stores and discloses personal data when users visit flashsim.xyz, create an account, purchase an eSIM or otherwise use our services.

Flashsim provides digital eSIM products and mobile data plans for use in supported countries and regions. To provide these services, we may need to process certain personal data relating to our customers, their orders, devices and use of the Website.

For the purposes of applicable data protection legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018, the data controller is:

TELECODE SOLUTIONS LTD Company Number: 17214997 Registered Office: Office 12 Initial Business Centre Wilson Business Park Manchester United Kingdom M40 8WN

Email: contact@flashsim.xyz

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed in connection with the Website, user accounts, eSIM purchases and activations, customer support, payment-related communications, marketing and any other interaction with Flashsim.

This Privacy Policy does not apply to websites, payment platforms, telecommunications networks or other services operated independently by third parties. Such third parties may process personal data under their own privacy policies.

3. Personal Data We Collect

We collect personal data directly from users, automatically through the Website and, where applicable, from our payment, technical and telecommunications partners.

When a user creates an account or purchases an eSIM, we may collect their name, email address, account identifier, login information and communication preferences. We may also collect information concerning the user’s order, including the purchased eSIM plan, destination country or region, data allowance, validity period, price, currency, order status, activation status and transaction reference.

To provide the eSIM service, we may process technical information associated with the eSIM profile, including the eSIM identifier, QR-code delivery status, activation date, expiry date, network provider, data-plan status, remaining data allowance and information necessary to investigate connectivity or activation issues.

Where the Website provides a customer wallet or balance functionality, we may process information about wallet top-ups, balances, deductions, refunds and transaction history.

Payments are generally processed by third-party payment service providers. Flashsim does not ordinarily store full payment card numbers, security codes or online banking credentials. We may receive limited payment information, such as the payment status, transaction identifier, payment method, card type, masked payment details, payment country, amount, currency and information relating to refunds, fraud alerts or chargebacks.

When users contact customer support, we process the information contained in their request, including contact details, correspondence, order references, screenshots, technical information and any other details voluntarily provided by the user.

When the Website is accessed, we may automatically collect the user’s IP address, browser type, operating system, device type, language settings, approximate location based on the IP address, date and time of access, pages viewed, referral source, session identifiers and technical or security logs.

We do not intentionally collect special categories of personal data, such as health information, biometric data, political opinions, religious beliefs or information about a person’s sex life. Users should not provide such information unless it is strictly necessary for a specific request.

4. Purposes of Processing

We process personal data primarily to provide the services requested by users. This includes creating and managing user accounts, processing orders, confirming payments, issuing eSIM profiles, delivering QR codes, activating data plans, displaying plan status and data usage, providing customer support and processing refunds.

We may also process personal data to operate, maintain and improve the Website, investigate technical errors, analyse service performance and develop new functionality.

Personal data may be used to protect Flashsim, its users and its service providers against fraud, unauthorised transactions, account misuse, cybersecurity threats, payment disputes and other unlawful or suspicious activity.

We also process information where necessary to comply with accounting, tax, consumer protection, telecommunications, regulatory and other legal obligations. Personal data may be used to establish, exercise or defend legal claims and to enforce our contractual terms.

Where permitted by law, we may use contact details to send information about Flashsim products, promotions or updates. Users may unsubscribe from marketing communications at any time. Service-related communications, such as order confirmations, activation instructions and security notices, are not considered marketing.

5. Legal Bases for Processing

Where the UK GDPR applies, we process personal data on one or more of the following legal bases.

Most processing relating to eSIM orders, account management, payment confirmation, activation, customer support and refunds is necessary for the performance of a contract with the user or to take steps at the user’s request before entering into a contract.

Certain processing is necessary for compliance with legal obligations, including tax, accounting, regulatory and law-enforcement requirements.

We may process personal data on the basis of our legitimate interests, including operating and improving the Website, preventing fraud, securing our systems, managing payment disputes, maintaining business records and protecting our legal and commercial interests. We only rely on legitimate interests where those interests are not overridden by the rights and freedoms of the user.

Where required by law, we rely on consent, including for certain cookies, analytics technologies and marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Payment Processing

Payments made through the Website may be processed by third-party payment service providers, banks, card schemes or digital wallet providers.

These entities may act as independent data controllers and may be required to process personal data for payment execution, fraud prevention, identity verification, regulatory compliance, dispute management and chargeback handling.

Flashsim is not responsible for the independent privacy practices of payment providers. Users should review the privacy notice of the relevant payment provider before submitting payment information.

7. Disclosure of Personal Data

We may disclose personal data to eSIM platforms, mobile network operators, roaming partners and telecommunications providers where necessary to issue, activate, maintain and support an eSIM service.

We may also share information with payment processors, acquiring banks, card schemes and fraud-prevention providers for the purposes of processing payments, preventing fraudulent transactions and managing refunds or disputes.

Personal data may be processed by providers of hosting, cloud infrastructure, cybersecurity, email delivery, customer support, website monitoring, analytics and other technical services. Such providers may only process personal data for the purposes of providing services to Flashsim and must apply appropriate confidentiality and security protections.

We may disclose information to professional advisers, including lawyers, accountants, auditors, insurers and consultants, where reasonably necessary.

Personal data may also be disclosed to courts, regulators, law-enforcement bodies, tax authorities or other public authorities where disclosure is required by law or necessary to protect our rights, investigate unlawful activity or defend legal claims.

In the event of a merger, restructuring, acquisition, investment or sale of all or part of our business, personal data may be disclosed to relevant counterparties and advisers, subject to appropriate confidentiality safeguards.

We do not sell personal data to third parties.

8. International Data Transfers

Flashsim provides eSIM services that may involve telecommunications and technical partners located outside the United Kingdom. Personal data may therefore be stored or processed in countries that do not provide the same level of data protection as the United Kingdom.

Where required by law, we use appropriate transfer safeguards, including UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the European Commission Standard Contractual Clauses or another lawful transfer mechanism.

We may also implement additional technical, organisational or contractual safeguards depending on the nature of the transfer and the country in which the recipient is located.

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Account information is generally retained while the account remains active and for a reasonable period after closure. Order, payment, wallet, invoice and accounting records may generally be retained for up to six years where required for legal, tax or accounting purposes.

eSIM provisioning, activation and service records may be retained for the duration of the relevant data plan and for a reasonable period afterwards to deal with technical support, refunds, fraud, disputes and legal claims.

Customer support communications may generally be retained for up to three years after the relevant matter has been resolved. Technical and security logs are generally retained for a shorter period unless they are required for the investigation of an incident.

Information may be retained for a longer period where required by law, necessary in connection with legal proceedings or reasonably required to investigate fraud, chargebacks, abuse or security incidents.

When personal data is no longer required, it will be deleted, anonymised or securely restricted from further use.

10. Cookies and Similar Technologies

The Website may use cookies and similar technologies to provide essential Website functions, manage user sessions, remember preferences, protect transactions and maintain security.

We may also use analytics, functionality or marketing cookies where permitted by law. Where consent is required, such cookies will not be activated until the user has provided consent.

Users may manage their cookie preferences through the cookie banner or browser settings. Blocking certain cookies may affect the operation of the Website, account access or checkout functionality.

Further information may be provided in a separate Cookie Policy.

11. Marketing Communications

Where permitted by law, Flashsim may send users information about eSIM plans, new destinations, special offers and other related services.

Marketing communications may be sent on the basis of consent or, where legally permitted, to existing customers in relation to similar services.

Users may unsubscribe at any time by using the unsubscribe link contained in the relevant message or by contacting contact@flashsim.xyz.

Unsubscribing from marketing will not prevent users from receiving essential communications concerning their account, orders, payments, eSIM activation, service status or security.

12. Automated Fraud Prevention

We may use automated tools to identify potentially fraudulent, abusive or high-risk activity.

These tools may consider transaction amount, purchase frequency, IP address, device information, payment-provider risk indicators, unusual account activity, failed payment attempts, refund history or chargeback information.

An order may be delayed, declined or referred for manual review where suspicious activity is identified.

Flashsim does not ordinarily make decisions based solely on automated processing that produce legal or similarly significant effects on users. Where applicable law provides rights in relation to automated decisions, the user may request human review or challenge the relevant decision.

13. Data Security

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access restrictions, authentication controls, encrypted communications, secure hosting, security monitoring, data minimisation, confidentiality obligations, backups and incident-response procedures.

No electronic system or internet transmission can be guaranteed to be completely secure. Users are responsible for keeping their account credentials, eSIM QR codes and activation details confidential and should contact us immediately if they believe such information has been compromised.

14. User Rights

Subject to applicable data protection law, users may request access to their personal data and obtain information about how it is processed.

Users may also request correction of inaccurate information, completion of incomplete information, deletion of personal data or restriction of processing in certain circumstances.

Where processing is based on legitimate interests, users may have the right to object. Users have an absolute right to object to processing for direct marketing purposes.

Where processing is based on consent, consent may be withdrawn at any time. Where processing is based on a contract or consent and carried out by automated means, users may also have a right to data portability.

Certain rights are not absolute. We may continue to retain or process information where this is required by law, necessary to perform a contract, necessary for the establishment or defence of legal claims or otherwise permitted under applicable law.

Requests may be submitted to contact@flashsim.xyz. We may request additional information to verify the identity of the person making the request.

We will generally respond within one month, although this period may be extended where permitted by law due to the complexity or number of requests.

15. Children

The Services are intended for individuals who are legally capable of entering into a binding contract or who use the Services with the involvement and permission of a parent or legal guardian.

We do not knowingly collect personal data directly from children where parental or guardian consent is legally required.

Where a parent or guardian purchases an eSIM for a child, the parent or guardian is responsible for the purchase and for supervising the child’s use of the Services.

If you believe that a child has provided personal data without appropriate authorisation, please contact us.

16. Third-Party Links and Services

The Website may contain links to external websites, applications, payment pages or services operated by third parties.

Flashsim does not control the processing activities of such third parties and is not responsible for their privacy practices, content or security. Users should review the relevant third-party privacy policy before submitting personal data.

17. Complaints

Users who have concerns about the processing of their personal data should first contact us at contact@flashsim.xyz so that we can investigate the matter.

Users also have the right to lodge a complaint with the Information Commissioner’s Office:

• Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF United Kingdom
• Telephone: 0303 123 1113
• A complaint may also be submitted to another competent data protection authority where applicable.

18. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes to the Website, our Services, legal requirements or our processing activities.

The updated version will be published on the Website with a revised effective date. Where changes are material, we may provide additional notice through the Website, by email or through the user account.

Continued use of the Services after the updated Privacy Policy becomes effective means that the user has been informed of the revised processing practices. Where consent is required for any new processing activity, we will obtain it separately.

19. Contact Details

Questions, requests and complaints concerning this Privacy Policy or the processing of personal data may be sent to:

TELECODE SOLUTIONS LTD Office 12 Initial Business Centre Wilson Business Park Manchester United Kingdom M40 8WN

Email: contact@flashsim.xyz