Privacy Policy
Privacy
Policy
Information privacy is about giving
individuals some control over when, how and to what extent information about
themselves is communicated to others.
the provider of the SimTravellers service, is committed to providing you with
privacy safeguards that are consistent with your right to choose whether you
wish to provide information about yourself, and if you do provide it, the
nature and quality of that information. By using the website and services, you
agree to the collection and use of your information in accordance with this
Privacy Policy. If you do not agree with this Privacy Policy, please do not use
the website or the services.
Personal data we
collect and purpose for processing of personal data
Personal data means any information
relating to an identified or identifiable natural person.
SimTravellers will collect personal data from you that is
necessary for the purposes of supplying to you the service you subscribe to,
such as name, postal address, email address, and telephone number. SimTravellers
may also collect information about your
location. This information is based on the cell tower locations used to
transmit your mobile phone call, or the local country access numbers dialed to
use your phone card.
In certain jurisdictions, we may
ask for a government issued personal identification number (ID) in limited
circumstances including when setting up a wireless account and activating your
device as required by law.
Except as provided herein, SimTravellers
will not provide your personal data to any other person unless we ask you and
you agree, or unless we are forced to do so by law.
Children’s
personal data
We understand the importance of
taking extra precautions to protect the privacy and safety of children using
SimTravellers products and services. Children under the age of 16 in EU, or
equivalent minimum age in the relevant jurisdiction, are not permitted to use
SimTravellers services, unless their parent provided verifiable consent. If we
learn that we have collected the personal information of a child under 16, or
equivalent minimum age depending on jurisdiction, outside the above
circumstances we will take steps to delete the information as soon as possible.
If at any time a parent needs to access, correct, or delete data associated
with child, they may contact us through our Contact page.
Processing of
special categories of personal data
SimTravellers will not collect or
use information revealing your racial or ethnic origin, political opinions,
religious or philosophical beliefs, or trade union membership, and the
processing of genetic data, biometric data for the purpose of uniquely
identifying a natural person, data concerning health or data concerning a
natural person’s sex life or sexual orientation, or any other information
considered sensitive.
Non-personal
Information
SimTravellers may automatically
collect non-personal information about you. This includes but not limited to
technical information about your mobile device, system and application
software, and peripherals, the type of internet browser and IP address you use
and the site which linked you to the TravelSim website. This information is
used to assist Top Connect in providing you with an effective website.
SimTravellers uses non-personally
identifiable information for internal purposes and to help us interact with
visitors to the website. SimTravellers may also share non-personally
identifiable information in the aggregate form with third parties to illustrate
trends and patterns. You cannot be personally identified from this information.
What do we use
for and disclose your personal date
SimTravellers will use your
personal data for customer service, to provide you with information that you
may request, and to customize your experience on the website or with the
service. Your personal data is used by SimTravellers to respond to your
requests, process your transactions, tailor offerings to you, and for general
internal business purposes.
SimTravellers will use your
financial information (bank’s account number, payment card number and other
electronic payment measure’s data) to bill you for products or otherwise
process your transactions. By making a purchase on the website or using the
services, you consent to SimTravellers providing your financial information to
Top Connect’s billing service providers (credit card processor Adyen, PayPal)
and to such third parties as SimTravellers determines for processing your
transactions. These third parties may include the credit card companies and
banking institutions used to process the transaction. We require all third
parties to have appropriate technical and operational security measures in
place to protect your personal data, in line with EU law on data protection
rules.
SimTravellers operates businesses
in multiple jurisdictions. We require all services providers to process your
information in a secure manner and in accordance with EU law on data
protection. We utilize standard means under EU law to legitimize data transfers
outside the EU.
If you have given additionally your
consent, SimTravellers may use your personally identifiable information to
contact you with information it thinks you would be interested in. If you do
not want to receive this information, indicate that SimTravellers may not do so
at the point on the website, where you give SimTravellers your personally
identifiable information. If you change your mind later, you may contact us
through our Contact page. Email messages will also provide you with an
opportunity to opt-out of receiving this information. Please note that changes
to your preferences may not be effective immediately. Please note that your
removal from these communications will only apply to the processing of your
data in the future and not to data that have already been processed as provided
in this Privacy Policy.
Legal ground for
processing personal data
Legal grounds for processing your
personal data are:
- processing
is necessary for the performance of a contract to which the you are a
party or in order to take steps at your request prior to entering into a
contract;
- processing
is necessary for compliance with a legal obligation to which SimTravellers
is subject;
- by
accepting this privacy policy, you give consent for the processing of your
personal data for sending you our information and offers.
If you do not provide personal data
referred in clause 2, SimTravellers will not be able to provide its services to
you.
Community
Functions
The website and services may make
available to its users chat rooms, forums, message boards, and/or other
community functions. Remember that any information you disclose in these areas
becomes public information and you should exercise caution when deciding to
disclose your personal, financial or other information.
Personal data
security
SimTravellers will take reasonable
steps to ensure that the data we collect from you, use or disclose is accurate,
complete and up-to-date.
SimTravellers will take all
reasonable steps to ensure that the personal identifiable information we hold
about you is protected from misuse and loss or from unauthorized access,
modification or disclosure.
The data you provide to us is
protected using SSL (Secure Socket Layer) technology. SSL is the industry
standard method of encrypting personal information and credit card details so
that they can be securely transferred over the Internet.
SimTravellers will also take
reasonable steps to destroy or de-identify your personal data when we no longer
need it and it is not necessary retain data to comply with applicable laws.
Please note that we retain personal
data till it is necessary to provide SimTravellers services or till we have a
legal obligation to process it.
To determine the appropriate
retention period, we consider the amount, nature and sensitivity of the
personal data and the purposes for which we process it. We must also consider
periods for which we might need to retain personal data in order to meet our
legal obligations or to deal with complaints, queries and to protect our legal
rights in the event of claims being made.
Your Data
Protection Rights
Under certain
circumstances, by law you have the right to:
- Request
information about
whether we hold personal information about you, and, if so, what that
information is and why we are holding or using it.
- Request
access to
your personal data (data
subject access request). This enables you to receive a copy of
the personal data we hold about you.
- Request
correction of
the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected.
- Request
erasure of
your personal data. This enables you to ask us to delete or remove
personal data where there is no reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data
where you have exercised your right to object to processing.
- Object
to processing of
your personal data where we are relying on a legitimate interest (or those
of a third party) and there is something about your particular situation,
which makes you want to object to processing on this ground. You also have
the right to object when we are processing your personal information for
direct marketing purposes.
- Object
to automated decision-making including profiling, that is not to be
subject of any automated decision-making by us using your personal data or
profiling of you.
- Request
the restriction of
processing of your personal data. This enables you to ask us to suspend
the processing of personal data about you, for example if you want us to
establish its accuracy or the reason for processing it.
- Request
transfer of
your personal data in an electronic and structured form to you or to
another party (commonly known as a right to “data portability”). This enables
you to take your data from us in an electronically useable format and to
be able to transfer your data to another party in an electronically
useable format.
- Withdraw
consent.
Then you have provided your consent to the collection, processing and transfer
of your personal information for a specific purpose, you have the right to
withdraw your consent for that specific processing at any time. Once we
have received notification that you have withdrawn your consent, we will
no longer process your data for the purpose or purposes you originally
agreed to, unless we have another legitimate basis for doing so.
If you want to exercise any of
these rights, then you may contact us through our Contact page, or contact our
Data Protection Officer by mail :[email protected]
You can check and correct some of
your personal data details after logging onto the website with your account as
well.
Anonymity
SimTravellers is committed to
allowing our customers to conduct their activities through any of the services
we provide without being required to identify themselves. In some
circumstances, such as providing us with credit card details, we obviously
cannot deal with you anonymously. However, unless there are good practical or
legal reasons that require you to be identified, we will give you the option of
operating anonymously or pseudo-anonymously.
Cookies, site
tracking and links
A cookie is a piece of data
temporarily stored on the user’s hard drive containing information about the
user. A cookie contains your contact information and information to allow us to
identify your computer using TravelSim services. The cookie helps the user to
save time. For instance, by setting a cookie on our site, you do not have to
log in using your account more than once during each visit, thereby saving time
while on our site. You can choose to accept or decline cookies. Most web
browsers automatically accept cookies, but you can usually modify your browser
setting to decline cookies if you prefer. This may prevent you from taking full
advantage of the website.
We use tracking software to monitor
client traffic patterns and site usage to help us develop the design and layout
of the websites. This software does not enable us to capture any personal data.
This website may contain links to
other sites. Please be aware that SimTravellers is not responsible for the
privacy practices of such other sites. This privacy statement applies solely to
information collected by this website.
Changes to the
Privacy Policy
SimTravellers reserves the right to
change the terms of this Privacy Policy. Any changes will be posted on this
page. Notification will be sent also by email.