Privacy Policy

Introduction

DVN LTD, trading as SimmyFix ("we", "our", "us"), respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your information when you:

• Visit our website at www.simmyfix.com
• Use our eSIM services
• Interact with our platform
• Communicate with us in any way

We are the data controller and responsible for your personal data. Our contact details are:

DVN LTD (SimmyFix)
71-75 Shelton Street, Covent Garden
London, United Kingdom, WC2H 9JQ
Email: [email protected]

1. Personal Data We Collect

We collect and process the following categories of personal data:

1.1 Identity & Contact Data

• First name and last name
• Email address
• Phone number (optional)
• Billing address
• Account username

1.2 Financial Data

• Payment card details (processed securely via our payment providers)
• Transaction history
• Purchase records

1.3 Technical & Usage Data

• IP address
• Browser type and version
• Device information
• Operating system
• Time zone setting
• Location data
• Login data
• Service usage statistics

1.4 Marketing & Communications Data

• Marketing preferences
• Communication preferences
• Customer service interactions

2. How We Collect Your Data

We use different methods to collect data from and about you, including:

2.1 Direct Interactions

• When you create an account
• When you purchase our services
• When you contact our support team
• When you subscribe to our newsletters
• When you provide feedback or reviews

2.2 Automated Technologies

• Cookies and similar tracking technologies
• Server logs and usage data
• Device information collection
• Location data (with your consent)

2.3 Third Parties

• Payment processors
• Analytics providers
• Telecommunications partners
• Identity verification services

3. Legal Basis for Processing

Under the UK GDPR, we must have a legal basis for processing your personal data. We rely on the following legal bases:

3.1 Contract Performance

Processing necessary for the performance of our contract with you, including:

• Account creation and management
• Service provision and delivery
• Payment processing
• Customer support

3.2 Legitimate Interests

Processing necessary for our legitimate interests, including:

• Service improvement and development
• Fraud prevention and security
• Analytics and performance monitoring
• Business development and marketing

3.3 Legal Obligation

Processing necessary for compliance with legal obligations, including:

• Tax and accounting requirements
• Data protection obligations
• Law enforcement requests
• Regulatory compliance

3.4 Consent

Processing based on your explicit consent, including:

• Marketing communications
• Cookie usage (except essential cookies)
• Location data collection
• Processing of sensitive data

4. How We Use Your Data

We use your personal data for the following purposes:

4.1 Service Provision

• To create and manage your account
• To provide eSIM services
• To process payments and transactions
• To provide customer support
• To send service notifications

4.2 Service Improvement

• To analyze service usage patterns
• To debug and fix technical issues
• To develop new features
• To conduct research and analysis

4.3 Communication

• To respond to your inquiries
• To send service updates
• To provide marketing communications (with consent)
• To gather feedback

4.4 Security & Compliance

• To detect and prevent fraud
• To protect our services
• To verify identity
• To comply with legal obligations

5. Data Sharing and Transfers

We share your personal data with:

5.1 Service Providers

• Payment processors (Stripe)
• Telecommunications partners
• Cloud service providers
• Analytics services
• Customer support tools

5.2 Legal Requirements

We may disclose your data when required by law:

• Court orders
• Legal proceedings
• Regulatory requirements
• Law enforcement requests

5.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your data may be transferred. We will notify you of any change in ownership or data usage.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Secure data storage facilities
• Access controls and authentication
• Regular security assessments
• Staff training on data protection
• Incident response procedures

While we implement safeguards, no system is 100% secure. We cannot guarantee absolute security of your data.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

• Active accounts: Data retained while your account remains active
• Inactive accounts: Data retained for 12 months after last activity
• Financial records: Retained for 7 years as required by law
• Marketing data: Retained until you withdraw consent
• Technical logs: Retained for 90 days

After the retention period expires, your personal data will be securely deleted or anonymized.

8. Your Legal Rights

Under data protection laws, you have the following rights:

• Right to Access: Obtain confirmation if we process your data and request a copy
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data in certain circumstances
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Rights Related to Automated Decision Making: Not be subject to decisions based solely on automated processing

To exercise your rights, contact us at [email protected]. We will respond within one month. You also have the right to complain to the ICO (www.ico.org.uk).

9. International Transfers

We may transfer your data to countries outside the UK/EEA. When we do, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the UK/EU authorities
• Binding corporate rules for transfers within our group
• Specific derogations for limited circumstances

Contact us for more information about specific transfers and safeguards.

10. Cookies and Tracking

We use cookies and similar technologies on our website. A cookie is a small text file stored by your browser when you visit our website. We use cookies for the following purposes:

10.1 Cookie Categories

Essential Cookies (Always Active)

These cookies are necessary for the website to function and cannot be disabled in our systems.

• Authentication and session management
• Security features
• Load balancing
• Basic functionality

Analytics Cookies (Optional)

These cookies help us understand how visitors interact with our website.

• Google Analytics for website traffic analysis
• Page performance monitoring
• User behavior patterns
• Error tracking and debugging

Marketing Cookies (Optional)

These cookies are used to track visitors across websites for advertising purposes.

• Advertising targeting
• Campaign effectiveness measurement
• Social media integration
• Cross-device tracking

Personalization Cookies (Optional)

These cookies allow us to remember your preferences and provide enhanced features.

• Language preferences
• Country/region settings
• User interface preferences
• Previous search history

10.2 Cookie Consent

When you first visit our website, you will see a cookie consent banner. You can:

• Accept all cookies
• Customize your cookie preferences
• Reject optional cookies (essential cookies will still be used)
• Change your preferences at any time using the "Cookie Settings" link in our footer

10.3 Managing Cookies

You can control and manage cookies in several ways:

• Browser Settings: Most browsers allow you to refuse cookies or delete existing ones
• Cookie Settings: Use our cookie preference center (link in footer)
• Opt-out Links: Visit individual service provider opt-out pages
• Browser Extensions: Use privacy-focused browser extensions

Please note: Blocking essential cookies may affect the functionality of our website and services.

10.4 Third-Party Cookies

Some cookies are placed by third-party services that appear on our pages:

• Google Analytics: Website analytics and performance monitoring
• Google Tag Manager: Tag and code management
• Payment Processors: Secure payment processing

These third parties have their own privacy policies and cookie practices. We recommend reviewing their policies for more information.

11. Children's Privacy

Our services are not intended for children under 18. We do not knowingly collect data from children. If you become aware that a child has provided us with personal data, please contact us.

12. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by:

• Posting the new policy on our website
• Sending an email notification
• Displaying a notice in your account

Your continued use of our services after changes means you accept the updated policy.

13. Contact Us

For any questions about this privacy policy or our data practices, please contact us at:

DVN LTD (SimmyFix)
71-75 Shelton Street, Covent Garden
London, United Kingdom, WC2H 9JQ
Email: [email protected]