You can see our previous Privacy Policy here.
TABLE OF CONTENTS
Section 3: Personal Data And Other Data We Collect Automatically
Section 4: The Purposes and Our Legal Bases For Processing Your Personal Data
Section 6: Cookies, Software Development Kits, and Other Tracking Technologies
Section 12: Children’s Privacy
INTRODUCTION AND SCOPE
This eSim App Privacy Policy (“Privacy Policy”) is delivered on behalf of Municorn Limited (“we”, “us”, and “our”) and governs the Personal Data (as defined below) and other data collected from or processed about you when you use the eSIM Virtual Mobile Travel App, which allows customers to purchase and activate eSIMs for global mobile data usage (“eSim App”), including by downloading, installing, registering with, accessing or otherwise using the application (collectively referred to herein as “Use”).
We provide this Privacy Policy to explain our practices for collecting, using, processing, and disclosing the Personal Data and other data we process about eSim App users (“users”, “you”, or “your”, as applicable), and to tell you about the rights you may have in relation to your Personal Data and choices you may be able to make in relation to it.
By Personal Data we mean (i) information that is associated with an identified or identifiable natural person, and (ii) protected as personal data under applicable data protection laws.
Please read this Privacy Policy carefully to understand our privacy practices. We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.
By accepting this Privacy Policy, you acknowledge that you understand and agree to the processing of your Personal Data and other information as described in this Privacy Policy.
If you do not wish to have your data processed in accordance with this Privacy Policy, please refrain from using the eSim App.
This Privacy Policy also applies to our website available at https://municornesim.com/, which forms part of the eSim App.
Questions? If you have any questions about this Privacy Policy or eSim App, please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com. For additional contact information, please see Section 14: How to Contact Us.
U.S. State Supplements:
This Privacy Policy is designed to comply with data privacy laws across the United States, including:
California Consumer Privacy Act (CCPA),
Colorado Privacy Act (CPA),
Connecticut Data Privacy Act (CTDPA),
Virginia Consumer Data Protection Act (VCDPA),
Texas Data Privacy and Security Act (TDPSA),
Tennessee Consumer Privacy Act (TCPA),
Oregon Consumer Privacy Act (OCPA) and other applicable state laws.
If you are a resident of California, please see our California Notice at Collection and Privacy Notice, which provides detailed information about your rights and additional disclosures specific to California.
If you are a resident of Colorado, Connecticut, Virginia, Texas, Oregon, Tennessee, or any other U.S. state with privacy laws, please see our U.S. State Privacy Supplement (Non-California). The rights granted to you under these laws are also outlined in this Privacy Policy. These include:
The right to access, correct, delete, or receive a copy of your personal data.
The right to opt out of the sale or sharing of your personal data, targeted advertising, and profiling with legal or significant effects.
You may exercise these rights by contacting our support team via the support chat available in the App or on our website, or through the in-app privacy settings, where available. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
1. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
TL;DR: We collect personal data directly from you, automatically through your use of the app, and from trusted third parties — only as needed to deliver and improve our services.
We may collect Personal Data from and about you:
Directly from you when you provide it to us, to provide the app’s services (contractual necessity).
Automatically when you Use eSim App, for app functionality and analytics (legitimate interest). Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
From third parties, for example, our service providers, partners and vendors, when necessary for service delivery or marketing (consent or contractual necessity).
2. PERSONAL DATA YOU PROVIDE TO US DIRECTLY
TL;DR: When you sign up, contact us, or interact with the app, you may share information like your name, email, mobile carrier, and login credentials.
You may provide Personal Data to us directly, or to service providers that act on our behalf, when you Use eSim App. The Personal Data you provide depends on which features of eSim App you Use and how you interact with the App.
Authentication Data. When you create or access your personal account:
If you're using Google, we may collect your name and email address through Google’s authentication API.
If you're using Apple, we may collect your name and email address based on your Apple ID sharing settings.
If you're signing up via email, you provide your email address and verify it with a one-time password sent to your inbox.
These credentials are stored in eSIM App to maintain your account and profile.
If you contact us or communicate with us, we will collect and receive records and copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted).
Mobile carrier.
Users under the minimum age defined in Section 12: Children’s Privacy must not provide personal information. Any data collected from users under the age limit will be deleted immediately upon discovery.
3. PERSONAL DATA AND OTHER DATA WE COLLECT AUTOMATICALLY
TL;DR: The app automatically collects technical and usage data — device info, IP address, log files, geolocation, in-app events, and (with your consent) advertising identifiers.
When you Use eSim App, we or third parties we permit to do so, may automatically collect certain information, including Personal Data, from you (this is subject to your consent where this is required by law). The information collected from you automatically when you Use eSim App may include:
Log file information. Log file information is automatically reported by your browser each time you make a request to access (ie, visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device. When you use eSim App, our servers automatically record certain log file information, including your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the eSim App, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our services.
Subscription and device data. Information related to your subscription and device used for technical authorization.
Marketing and cookies data. Collected through cookies and analytics services integrated into the App.
Device information. Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system and version, mobile network information, device type and device language.
App and country information. Information regarding the version of the app that you are using and the country version of the app store from which you downloaded eSim App.
Geolocation data. The state or country associated with your IP address.
In-app events. When you use our eSIM App, analytics tools automatically record your activity information (tutorial steps, levelling up, purchases, custom events, progression events, and method of limiting the processing of user data).
Usage details. Details of your Use of eSim App, including frequency of Use, areas and features of the application that you access and information regarding engagement with particular features of the app.
Details about your purchases. For example, details regarding the time you made certain purchases.
Payments. When enabling payment processing, you will integrate with Stripe. The payment account details are stored by Stripe, not by us. Payment links or QR codes may be generated and shared to facilitate payments.
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by eSim App, please follow the instructions below.
If you use an iOS device:
Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
Tap to turn off or turn on permission to track for eSim App.
If you use an Android device:
Open Settings app
Navigate to “Privacy” > “Ads”
Tap “Delete Advertising ID”
Tap it again on the next page to confirm.
Other than with respect to Image Data, we and third-parties we engage may use cookies, Software Development Kits (SDKs), and other tracking technologies to automatically collect the Personal Data set forth above. For more information regarding our use of these technologies, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.
4. THE PURPOSES AND OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
TL;DR: We use your data to run and improve the app, support you, communicate, personalize content, deliver marketing (with consent), and comply with legal obligations.
We may use your Personal Data for a variety of purposes depending on the category of Personal Data and the way you Use and interact with the eSim App, including the following:
To present to you and others with eSim App and its contents and any other information, products or services that you request from us, including to provide various features of the app and its functionality. We do so to provide you with the services according to our contractual obligation.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to eSim App (e.g., the Terms of Use). This is for the performance of our contract with you and for our legitimate interests in performing and enforcing our contracts with you.
To customize our product and service offerings to you, for example, offering pricing personalization and discounts. In doing so, we make automated decisions using device type and device language data. Where required by law, we rely on your consent to offer such personalization and/or offer you the opportunity to opt out.
To provide you with customer and technical support, investigate your concerns, respond to your inquiries, and to monitor and improve our responses to your and other users’ inquiries in relation to eSim App. It is our legitimate interest to provide you with high-quality support.
To communicate with you, such as to notify you about changes to eSim App or any products or services we offer or provide through eSim App, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our contractual obligation to keep you informed about your subscription and your account and otherwise in our legitimate interests of keeping you informed about your eSim App account.
To conduct research, analytics, and monitor performance and other metrics regarding eSim App and your Use of eSim App. This may include data regarding the total number of users of our app, traffic, and demographic patterns related to the use of our app. Where this data is collected through the technologies described in Section 6: Cookies, Software Development Kits, and Other Tracking Technologies and where required by law, we rely on your consent; otherwise, it is our legitimate interest to conduct analytics as it helps us understand our business metrics and improve our product.
To improve, test, and monitor the effectiveness of eSim App. It is our legitimate interest to conduct such analyses to understand our product and business metrics.
Geolocation data is collected in an aggregated, non-identifiable format for analytics and service enhancement. We do not use your precise location for any marketing purposes without your explicit consent.
To provide personalized content and information to you in relation to eSim App and so that we, and third parties on which we rely, can advertise to you. This may include using your Personal Data to build advertising audiences that we believe are similar to our user base, serving online ads to you, or engaging in other forms of advertising. Where required by law, we rely on your consent to engage in such activities and/or offer you the opportunity to opt-out. Please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies for more information.
To send marketing and promotional communications to you, such as via email, push notification or in-app messaging either with your consent or based on our legitimate interest. Please see Section 8: Your Choices About Our Communications With You for more information.
In any other way, as we may describe when you provide the information or otherwise at your direction or with your consent.
As permitted or required by law, including for auditing, fraud and security monitoring purposes.
We may use automated decision-making technologies, including profiling, to improve app functionality, provide personalized content, and optimize advertising. For example, automated profiling may be used to recommend features based on your usage patterns. These activities do not produce legal effects or similarly significant effects on you, unless we explicitly inform you otherwise and have a valid legal basis to do so.
You have the right to:
Request more information about any automated decision-making processes,
Object to profiling that is based on our legitimate interest, and
Request human intervention in cases where automated decisions produce legal or similarly significant effects on you, where applicable.
Where processing is based on legitimate interest, we ensure that our interests do not override your fundamental rights and freedoms. You may object to such processing at any time by contacting our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
5. TO WHOM WE DISCLOSE PERSONAL DATA
TL;DR: We share data with vetted service providers, analytics and advertising partners, and payment processors that help us deliver the eSIM App, as well as in legal or business-transfer situations.
We may disclose the information we process about you, including any Personal Data, as follows:
We may disclose your Personal Data and other collected information to third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing eSim App. Such service providers may include:
Microsoft Azure - subject to their Terms of Use;
eSim Go - subject to their Terms and Conditions.
We may disclose your Personal Data to third-party analytics providers and advertising partners or otherwise permit them to collect or access it. For more information, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.
These analytics providers may include:
Amplitude – subject to their Terms of Service.
AppsFlyer – subject to their Terms of Use.
Firebase – subject to their Terms of Service.
Appfigures – subject to their Terms of Use.
Facebook Pixel – subject to their Facebook Terms and Policies.
Google Ads – subject to their Google Ads Terms and Conditions.
Twilio SendGrid – subject to their Terms of Service.
LeadProm Media (trading as Merchanto) – subject to their Terms and Conditions.
Yuno - subject to their Terms and Conditions.
Braze – subject to their Terms of Service.
We may disclose your Personal Data in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of, or dissolved, including in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, or liquidation. In such cases, your Personal Data and any other collected information may be among the items sold, transferred, or otherwise disclosed as part of that transaction or proceeding.
We may disclose your Personal Data in response to legal requests and for purposes of preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
Payments and Data Processing. We do not collect, store, or directly process sensitive payment details such as credit card numbers, expiration dates, or CVV codes. All payment transactions are securely processed by third-party payment providers, including Stripe.
When making a payment, your payment information (such as card details, billing address, and other financial data) is provided directly to the relevant payment provider and is processed and stored by them in accordance with their own privacy policies and terms of service. We do not access or retain any sensitive payment information submitted through these payment forms.
While payment details are processed exclusively by these providers, we may receive and process limited transaction-related metadata, such as transaction IDs, payment status, or other non-sensitive identifiers. This information is used solely for purposes such as order confirmation, fraud prevention, service continuity, and compliance with applicable legal or regulatory requirements.
For more information, please review the Stripe Privacy Policy and Stripe Connected Account Agreement.
We encourage you to view the privacy policy of Stripe for comprehensive details on how your sensitive payment data is managed. For questions or further assistance, please contact our Support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
Some of the third-party service providers and partners we share data with are located outside the EU/UK. Section 11: Cross-Border Data Transfers explains the safeguards we have in place to protect your personal data during international transfers.
6. COOKIES, SOFTWARE DEVELOPMENT KITS, AND OTHER TRACKING TECHNOLOGIES
TL;DR: We and our partners use cookies, SDKs, and similar tools for analytics and advertising. You can manage your preferences through your device settings or by contacting us, and we honor Global Privacy Control signals.
Analytics providers. When you Use eSim App, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your Use of eSim App. We also use third-party analytics tools like Google Firebase, AppsFlyer, and Amplitude to help us measure traffic and usage trends for eSim App and for other purposes. Such analytics tools collect information via third-party SDKs incorporated into eSim App, which includes information about features of eSim App you visit or Use, your actions in eSim App, and information about your subscription. Such information may be used to provide content, advertising, or functionality or to measure and analyze ad performance on eSim App or other websites or platforms. Third parties may also use such information for their own purposes. For the avoidance of doubt, we do not use Image Data for advertising purposes.
Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your Use of the app over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so to limit such technologies. You can visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info to learn more about this interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program, and http://www.aboutads.info/appchoices for information on the DAA’s mobile app opt-out program. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests.
For users in the European Economic Area, the United Kingdom and the United States. You can opt out from processing of Personal Data via SDKs and other tracking technologies by contacting our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may send a request by email to esim-support@municorn.com.
You may find that some parts of the app may not function properly if you have refused certain tracking technologies, and you should be aware that disabling certain tracking technologies may prevent you from accessing some of our content. Your choices are typically device and browser-specific.
We honor Global Privacy Control (GPC) signals as required by U.S. and international privacy laws. GPC is a browser or device setting that allows you to control the sale or sharing of your personal data. If GPC is enabled on your device, we will process it as a valid opt-out request under applicable laws. For more information on enabling GPC, please visit globalprivacycontrol.org.
7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
TL;DR: You can access, correct, delete, or port your data, object to processing, withdraw consent, and file a complaint with a supervisory authority. Contact us to exercise these rights.
Access, modification, correction and erasure. You can contact our support team via the support chat available in the App or on our website to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
EEA/UK individuals. Individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the UK version of the EEA GDPR (“UK GDPR”) (collectively, the “GDPR”), including the rights specified below. You can exercise these rights by contacting us (for contact information, please see Section 14: How to Contact Us. We will do our best to accommodate your request or objection, but please note that not all rights are absolute.
Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, and to receive a copy of such Personal Data.
Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using eSim App features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
Erasure of your Personal Data: In certain circumstances, you may ask us to erase your Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use eSim App.
Right to portability of your Personal Data: In certain circumstances, you have the right to request us to receive any Personal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
Right to object to processing or otherwise using your Personal Data: You have the right to object at any time to the processing of your Personal Data where such processing is based on our legitimate interests, including the processing of your Personal Data for direct marketing purposes.
Please note that this right does not apply to processing that is necessary for the performance of a contract between you and us (such as providing the core functionality of the eSIM App). However, objecting to certain processing carried out based on legitimate interests, such as security, fraud prevention, or service improvement, may affect our ability to provide some features or services.
Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authorities here, and the UK’s supervisory authority (ICO) here.
Rights related to Automated Decision-Making and Profiling. You have the right to request more information about any automated decision-making processes. Apart from that, you may object to profiling that affects you, and you may request human intervention in cases where automated decisions produce legal or similar effects on you under applicable laws.
To learn more about your privacy choices and rights regarding our communication with you, please refer to Section 8.
Please keep in mind that we accommodate your requests free of charge. However, if your request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to act on the request.
Besides, in case of a vague request to exercise any of the aforementioned rights, we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse to grant your request.
Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your username or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Prohibited Content and User Responsibility
By using this app, you agree not to upload any illegal, harmful, or unlawful content, including but not limited to:
Personal data of third parties without their consent,
Sensitive personal data of third parties, such as medical, financial, or biometric data, unless you have explicit consent,
Infringing content, including but not limited to copyrighted material, trademark violations, or any content that breaches intellectual property rights,
Defamatory or offensive material, including hate speech, threats, or discriminatory content,
Pornographic, sexually explicit, or obscene content,
Fraudulent or deceptive content, such as phishing attempts, scams, or misleading information.
And other types of information that could be considered illegal.
Uploading such content is done at your own risk and responsibility. You are solely responsible for ensuring that the documents you upload do not contain illegal or unlawful material or content you do not have the right to share.
In the event that we detect unlawful content in the documents uploaded by users, we reserve the right to report such content to the relevant authorities for further investigation. This may include providing user-uploaded content or other relevant information to law enforcement or other regulatory bodies, as required by law.
We do not bear responsibility for any legal consequences arising from the uploading of prohibited content.
Manage your privacy rights. To enhance your experience, we provide in-app tools to manage your privacy rights, such as:
Accessing your personal data,
Deleting your account and associated data,
Managing consent for tracking and analytics technologies.
For additional assistance, please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
Requests related to personal or other data. If you are an individual in the EEA or UK, we will
respond to your requests without undue delay and at the latest within one month from the date
we receive your request. If your request is complex or if we receive a large number of requests,
we may extend this period by an additional two months. In such cases, we will inform you of the
extension and the reasons for the delay within the initial one-month period.
In any other case, we will process your requests related to personal data within 45 days from the
date we receive them. If additional time is required due to complexity or volume of requests, we
may extend this period by an additional 45 days. In such cases, we will notify you within the initial
45-day period.
You may submit your request through the support chat available in the App or on our website, or through the app’s privacy settings. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
8. YOUR CHOICES ABOUT OUR COMMUNICATIONS WITH YOU
TL;DR: You can’t opt out of essential service messages, but you can unsubscribe from marketing emails and turn off push notifications anytime.
Necessary communications. If you are using the eSim App, you may receive certain electronic communications from us (for example, in-app notices within the eSim App, push notifications, or emails). These communications are necessary, and you cannot opt out of receiving them, as they are required to perform our contract with you and/or are sent based on our legitimate interest in providing and maintaining the eSim App.
Such communications may include, but are not limited to: information related to your subscription and purchases (including invoices and payment confirmations), account and eSIM settings, usage and balance notifications (including data consumption and limit warnings), service updates, technical and security notices, and updates to our Privacy Policy or Terms of Use.
Marketing & Promotional Emails. Additionally, where permitted by applicable law, we may send you marketing and promotional communications by email relating to the eSIM App, including promotional offers, travel discounts, product updates, and announcements of new features. Where required by applicable law, we will obtain your consent before sending any marketing and promotional communications. You may opt out of receiving our marketing and promotional emails at any time by clicking the unsubscribe link included in any such email or by contacting our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com, without affecting the lawfulness of communications sent prior to your opt-out.
You will then be removed from the marketing email list; however, opting out of marketing emails will not affect your receipt of non-marketing, service-related/transactional emails, which are necessary for account administration and your use of the eSIM App.
Please note that we do not use your precise location for any marketing purposes without your explicit consent.
OTP Delivery. For authentication purposes, we may send you a One-Time Password (OTP) via email. These emails are also processed via the providers mentioned above and initiated only by user request (e.g., during login or identity verification).
Push Notifications. If you wish to opt out of push notifications, you can do so through your mobile device settings by tapping “Settings” -> “Notifications” -> Choose eSim App - > press the toggle to allow or forbid push notifications from the app.
9. DATA SECURITY
TL;DR: We use reasonable technical and organizational safeguards to protect your data, but no online system is 100% secure. We’ll notify you of any breach where required by law.
We use reasonable and appropriate information security safeguards to help keep your Personal Data and other data, secure and, in an effort, to protect it from accidental loss and unauthorized access, use, alteration and disclosure. We implement appropriate technical and organizational measures to protect your personal data, including encryption, secure servers, access controls, and regular security testing. We also require our third-party service providers to maintain equivalent safeguards.
Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to do our best to protect your Personal Data, we cannot guarantee the security of the collected information transmitted to or through the App or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed.
Any transmission of your Personal Data is at your own risk. We are not responsible for the circumvention of security measures contained in the App. Please understand that there is no ideal technology or measure to maintain 100% security.
The safety and security of your information also depend on you. For instance, we are not responsible for how you choose to share the information processed in your eSim App account, such as via social media services. We are not responsible for the functionality, privacy, or security measures of any other organization.
In the event of a personal data breach, we have procedures to promptly assess, contain, and remediate the breach. Where required by law, we will notify the relevant data protection authorities and affected users in accordance with GDPR and applicable laws.
We, and our partners, follow GSMA eSIM security and provisioning standards.
In the event of a personal data breach, we have procedures to promptly assess, contain, and remediate the breach. Where required by law, we will notify the relevant data protection authorities and affected users in accordance with GDPR and applicable laws.
If you believe your data has been compromised, please contact us immediately via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
10. DATA RETENTION
TL;DR: We keep your data only as long as necessary — account info until deletion, payment records for seven (7) years, and analytics in anonymized form.
We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy or until you request the deletion of your account, whichever comes first.
Specific retention periods include:
User account data: Retained until account deletion.
Payment and transactional data: Retained for seven (7) years for compliance with financial and tax regulations.
Analytics and usage data: Retained in anonymized form for business purposes.
You may request account deletion through the support chat available in the App or on our website, or by using the in-app functionality. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.
11. CROSS-BORDER DATA TRANSFERS
TL;DR: Your data may be processed outside your country, including in the U.S. We use safeguards such as Standard Contractual Clauses and the UK Addendum to keep it protected.
ESim is a global App. To operate our Services, your Personal Data may be transferred, stored, and processed in jurisdictions outside of your country of residence, primarily in the United States. Data protection laws in these countries may differ from the laws of your country of residence.
We use third-party service providers that operate global networks of data centers for hosting and infrastructure purposes. As a result, the processing of your Personal Data may be carried out in various locations, which is a necessary part of providing the Services to you.
Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.
Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.
Azure servers’ usage. As to the location of our servers, we use Azure servers located in the USA for eSim App operation and Google LLC multiregional servers locations, while our analytics operations are processed both on the servers provided by Azure and by Google LLC.
For further information please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
12. CHILDREN’S PRIVACY
TL;DR: The eSIM App is not intended for children under 13 (or under 16 in the EEA/UK). We don’t knowingly collect data from minors and will delete it if discovered.
General age limitation. eSIM App is not intended for or directed at children under 13, and we
do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly
allow such persons to Use eSIM App.
If you are a parent or guardian and believe we have collected information from your child who is under the age of 13, please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
Age limitation for EEA and/or UK individuals. You must be at least 16 years old in order to Use eSIM App. We do not allow Use of eSIM App by EEA and/or UK individuals younger than 16 years old. If you are aware of anyone younger than 16 Using eSIM App, please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com, and we will take the required steps to delete the information provided by such persons.
13. THIRD-PARTY WEBSITES AND SERVICES
TL;DR: We’re not responsible for the privacy practices of third-party sites or services linked from the eSIM App — please review their policies separately.
We are not responsible for the practices employed by any websites or services linked to or from eSim App, including the information or content contained within them. Where we have a link to a website or service, linked to or from eSim App, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.
14. HOW TO CONTACT US
TL;DR: For any privacy questions or to exercise your rights, contact us via chat or email.
General contact details. If you have any questions about this Privacy Policy or eSim App, please contact our support team via the support chat available in the App or on our website. If the support chat is unavailable, you may contact us by email at esim-support@municorn.com.
Data protection officer. If you are an individual in the EEA or the UK and you wish to exercise your rights under Section 7: Your Rights In Relation to Your Personal Data, or you have any questions about this Privacy Policy or eSim App, you can contact our data protection officer via the support chat available in the App or on our website. If the support chat is unavailable, you may contact our data protection officer by email at esim-support@municorn.com.
15. CHANGES TO OUR PRIVACY POLICY
TL;DR: We may update this Privacy Policy from time to time. If changes are material, we’ll notify you and, where required, ask for your consent.
The date this Privacy Policy was last revised is indicated at the top of the page. We modify or update this Privacy Policy from time to time. Some changes do not require your consent. However, if we determine that the changes may pose a risk to your rights and freedoms, we will ask for your consent to those changes separately from this Privacy Policy.