Last Updated: 14/03/2025

1. Introduction

Welcome to the “My Esim” app and website (hereinafter, the “Service”). This Privacy Policy (“Policy”) explains how Digital Growth Solutions LLC (“Company,” “we,” or “us”) collects, uses, stores, and shares your personal data when you use our Service. By accessing or using the Service, you acknowledge that you have read and understood this Policy and agree to be bound by it. If you do not agree with any part of this Policy, please do not use the Service.

2. Data We Collect

1. Account Information: When creating an account or purchasing an eSIM, we may request:

◦ First and Last Name

◦ Email Address

◦ Phone Number

2. Location Data:

◦ If you explicitly grant permission through your device settings (e.g., enabling “Precise Location”), we collect precise location data (GPS) to provide customized push notifications and location-based features.

◦ You can revoke this permission or disable precise location sharing at any time in your device’s settings.

◦ If you choose not to grant permission or disable precise location, the Service may only collect approximate location (e.g., city/country) or no location data at all, depending on your settings.

3. Transaction Data: Payment-related details (e.g., purchase amount) are primarily processed by Stripe. We do not store or handle your full card details.

4. Usage & Analytics Data: We utilize tools like Google Analytics to gather information about your interactions with the Service (e.g., pages visited, in-app actions). This information is generally aggregated to help us improve user experience.

3. How We Use Your Data

1. Service Provision: We use your personal data to complete the eSIM purchase, activate and manage your account, and provide customer support.

2. Notifications & Alerts:

◦ We may send push notifications related to your eSIM usage or your location (e.g., availability of new packages or offers), provided you have granted permission.◦ If you have chosen to enable “precise location,” you may receive more tailored location-based alerts.

3. Promotional/Marketing Purposes: If you consent, we may use your email or phone number to send mass emails/SMS with special offers, new products, or updates about the Service. You can opt out at any time.

4. Analytics & Service Improvement: We use analytics tools (e.g., Google Analytics) to understand how users interact with the Service, enabling us to enhance its features and performance.

5. Legal Compliance: We may process your data if required by law, court order, or governmental request, or if necessary to protect our legal rights.

4. Sharing Your Data with Third Parties

1. Stripe: Payments are processed through Stripe. We share only the necessary data (e.g., amount, transaction reference) to complete your purchase.

2. MailChimp & Similar Platforms: For sending newsletters or SMS (if you have consented), we share your email/phone number.

3. Google Analytics: We use Google Analytics for usage statistics, which generally involves aggregated or anonymized data about your activity on our website/app.

4. Other Service Providers: We may use additional third-party providers (e.g., hosting providers, software development partners) who process data on our behalf, under contractual obligations to protect it.

5. Legal Obligations: We may disclose data if required by law or if we believe in good faith that it is necessary to comply with legal obligations, protect rights, or prevent illegal activities.

We do not sell or rent your personal data to third parties for their own marketing purposes.

5. Data Retention

We retain your personal data for as long as you have an account with our Service and/or as necessary to provide our services (e.g., eSIM activation, purchase history). If you close your account or request deletion, we will delete or anonymize your data unless we are legally required to keep it (e.g., for accounting or tax obligations).

6. Your Rights

Under the GDPR (and other applicable laws), you have the right to:

• Access your personal data and request a copy.

• Rectify or update any inaccurate data.

• Erase (right to be forgotten), especially if there is no legal basis for retaining it.

• Restrict the processing of your data.

• Object to the processing of your data for direct marketing purposes.

• Data Portability, where technically feasible.

To exercise your rights or request more information, please contact us via email or phone (see Section 10).

7. Data Security and Transfers

1. Security Measures: We employ technical and organizational measures (e.g., TLS encryption, access controls) to protect your data.

2. Storage Location: Data is stored on servers within the European Union, but some third-party services (e.g., Google, MailChimp) may be based outside the EU. Where this occurs, we ensure appropriate safeguards (e.g., Standard Contractual Clauses) are in place, in accordance with applicable laws.

8. Children and Minors

Our Service is intended for adults (18+). We do not knowingly collect personal data from individuals under 16. If you are a parent/guardian and believe your child has provided us with personal information without your consent, please contact us so we can delete the relevant data.

9. Policy Updates

We may update this Privacy Policy whenever necessary. The “Last Updated” date at the top indicates when the latest changes were made. Any changes become effective upon posting the revised Policy on our Service. We encourage you to review this page periodically for the latest information.

10. Contact Us

If you have any questions about this Policy or wish to exercise your rights, please contact us:

• Email: support@myesim.gr

• Phone: 2102207969 (Monday to Saturday 9:00 – 21:00)

• Address: Digital Growth Solutions LLC, 30N Gould St, Sheridan – WY 82801, Sheridan County, Wyoming, USA

Thank you for using “My Esim”!