PRIVACY POLICY
Effective date: 18th October 2024
This privacy policy ('Policy') is intended to inform you about how your Personal Data will be handled by Cloud Telecommunications (S) Pte. Ltd. for the use of the Bropandaapplication ('Bropanda', 'the Application', 'we', 'us' or 'our'). It sets out the information including personal information detailed below relating to you or which you provide to us ('Personal Data') that will be collected and processed by Cloud Telecom and/or on its behalf by its third-party service providers when you contact us through our channels, such as our application, website or, once you have contracted for our Services. We are required to give you this information, including to inform you about your data protection rights.
By registering, using and/or visiting the Application, website, product, software, tool, data feed, and/or service (collectively the 'Services') you understand and agree to this Policy. We reserve the right to update this Policy at any time. If significant changes occur, we will notify you by posting a notice here, on our homepage, or via email. It is your responsibility to review this policy regularly and keep yourself up to date of the latest version.
APPLICABILITY OF THIS PRIVACY POLICY
End Users: Individuals who use and interact with the Services through their eSIMM ROAM account for personal purposes.
Business Users: Entities to whom Bropanda provides Services, and in turn, may provide us with personal information about their End Customers for business purposes.
End Customers: Individuals receiving Services ordered by other Bropanda account holders, such as when they transact or do business with a Business User.
Job applicants: Individuals submitting a job application to Bropanda.
WAYS PERSONAL DATA IS COLLECTED, DISCLOSED AND USED
We collect personal information in various ways depending on your interaction with us and our Services, including:
Directly from you: When you provide information, such as when registering an account, signing up for communications, placing an order, making a purchase, or contacting us via phone, email, or other methods.
Automatically: Through cookies, server logs, and similar technologies during your interaction with our Services or emails, where permitted by law or where you have consented.
From other sources: Including affiliates, business partners, service providers, online social networks, and publicly available sources. For instance, during a job application or employment, we may conduct a background check.
Data and systems are classified based on legal requirements, sensitivity, and business criticality to ensure proper protection. The "data controller" determines the purposes and means of processing personal information, while the "data processor" acts under the controller's instructions.
Bropanda as a Data Controller
Bropanda acts as a data controller when determining the purposes and means of processing personal data. As a data controller, Bropanda ensures compliance with data protection laws. Key activities include:
Direct Sign-ups: When users register directly with the Services, Bropanda is the data controller. This applies to:
B2C: End users who sign up directly for Bropanda's Services.
B2B: Business Users or End Customers signing up directly.
Services Delivery: Utilizing data to provide Bropanda's products and services.
Fraud Prevention: Detecting and monitoring fraudulent activities.
Legal Compliance: Meeting financial, legal, and regulatory requirements.
Services Improvement: Enhancing Services based on data analysis.
Job Application Processing: Managing personal data from job applicants.
Bropanda as a Data Processor
In certain cases, Bropanda functions as a data processor, processing data on behalf of Business Users and under their instructions. This includes:
B2B End Customers: Acting as a data processor for End Customers of Business Users in a B2B setting.
Services Execution for Business Users: Carrying out instructions from Business Users, such as account creation and distributing eSIMs to End Customers.
When operating as a data processor, users should refer to the privacy policy of the respective data controller (the Business User) for details on data handling. eSIMM ROAM strictly follows the controller's instructions, ensuring the confidentiality and security of processed data in compliance with data protection laws and contractual obligations.
PERSONAL DATA WE COLLECT
Bropanda may collect a range of Personal Data which means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The types of Data we collect may include:
Activities
Personal Data Collected
Purposes
Account Registration - Name
- Contact information (Including: Phone number, email)
- Activities/actions performed while logged in
To offer account-related features to users. This enables quick checkouts and allows us to store your preferences for fast checkout. Also allows us to perform contractual obligations to users. Biometric information Biometric identifiers from photo IDs and selfies. Processed with users' consent to confirm identity through the eKYC process required by law. Business Users - Name
- Contact information (Including email, phone number, and physical address of employees of our Business Users with whom we may interact).
To contact our clients and communicate with them concerning normal business administration such as projects, Services, and billing. Necessary Online Tracking Technologies - Cookies: Small pieces of information that a website sends to a computer's hard drive while a website is viewed.
- Clear GIFs: Pixels that are loaded by your browser when you access a website.
- Data collected: browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, and/or a date/time stamp for visitors.
To enable efficient operation of our website. Non-Essential Tracking Technologies We may use tracking technologies (e.g., cookies, pixels) on our website to collect analytics, monitor your interactions, and support behavior-based advertising. These tools may gather information like your browser type, operating system, IP address, domain, click activity, referring website, and visit timestamps. We or third parties may also collect data across different websites to serve ads on our site or others. Third-party cookies are used with consent and when required by law. Demographic Information Personal information (e.g., age and/or location) To provide tailored Services. Job Applicants - Personal and contact information
- Education
- Job history
To assess candidates for potential roles and, in some cases, are legally required to collect information on employees or applicants. To ensure efficient staffing and workforce management. Feedback/Support Name and email address and the feedback or support content sent to us to provide you with a reply. To receive and act upon your feedback and support needed. Mobile devices Unique identifying information broadcast from your device when visiting our website. To identify unique visitors and monitor visits to our website. Placing of Orders Name, billing address, shipping address, email address, phone number, and payment card number when you place an order. To perform our contractual obligations to provide you with our Services. Partner Promotion Information provided as part of a co-branded promotion with another company. To fulfill our promotions. Surveys Information provided through a survey. Survey by a third-party service provider will follow the third party's privacy policy. To understand users' opinions and collect relevant information. DATA RETENTION
In general, we will store your Personal Data in accordance with our obligations under this Policy for as long as we have a relationship with you plus a reasonable period after that, if required or permitted by law. The criteria used to determine the retention periods include: the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.
USE OF PERSONAL INFORMATION
Users' Personal Information may also be used for the purposes stated below:
Identify users visiting our website.
Provide products, Services, and process returns.
Improve our Services and product offerings.
Simplify the checkout process.
Conduct analytics and performance evaluations.
Communicate with you to address requests, inquiries, issues, or feedback.
Send marketing materials, including information about products, Services, sales, and promotions from us or our partners.
Detect and prevent malicious, fraudulent, or illegal activities, including policy violations and security incidents.
Debug and fix errors affecting the functionality of our website and Services.
Comply with legal obligations, exercise our rights, and defend against legal claims.
Manage internal administration and business relationships.
Fulfil other purposes with your consent.
Collect and process information based on consent, contract performance, legal obligations, or legitimate business interests, depending on the context.
SHARING OF PERSONAL INFORMATION
Affiliates and Acquisitions: We may share your information with corporate affiliates (e.g., parent company, subsidiaries, joint ventures) or in the event of a company acquisition, including during negotiations.
Legal and Compliance Disclosures: We may disclose information in response to legal requests like subpoenas, court orders, or to comply with laws. This also applies when protecting our rights, defending legal claims, investigating potential fraud, illegal activities, safety concerns, or enforcing policies. Additionally, we may share information when requested for product shipments or Services through third-party intermediaries.
Partner Promotions: If you participate in a promotion co-sponsored by a third party, your information will be shared with both us and the partner. Their use of your data will follow their own privacy policy.
Services Providers: We may share information with Services providers who assist in running our website, supporting business operations, processing payments, and fulfilling orders.
Disclosures with Consent: We may share your information with third parties when we have your explicit consent or direction.
USERS' RIGHTS
Depending on your location and applicable laws, you may have the following rights:
Access Your Data: You can request details on the personal information we collect, use, or disclose about you, and in some cases, receive your data in a portable, machine-readable format.
Verify and Correct Data: You can request corrections to any inaccurate personal information we hold. It is your responsibility to update your own information via your account. If the website does not allow changes, you can contact us to request modifications. Note that historical data may be retained in backups as allowed by law.
Request Deletion: You can request the deletion of your personal information.
Withdraw Consent: You can withdraw previously given consent for data processing at any time.
Object to Data Processing: You have the right to object to the processing of your personal information if it is based on legal grounds other than your consent.
Online Tracking: We do not recognize "Do Not Track" signals.
Please note that these rights may not apply in all situations, and we may deny requests if allowed by law or if we cannot verify your identity. We will not discriminate against you for exercising your rights.
To exercise any of these rights, or appeal a decision, contact us using the information below or via our "Contact Us" page. You may need to verify your identity by providing details like your name or recent purchases, and in some cases, a signed declaration. We will make reasonable efforts to fulfill your request, correct, or delete your data.
You may also appoint an authorized agent to submit privacy requests on your behalf. Agents must provide a signed document proving their authority.
You have full control over your personal data and can manage your preferences, account, and data processing as follows:
Unsubscribing from Marketing Emails: Opt-out from marketing emails by logging into your account, navigating to Profile settings, and toggling the promotional emails option.
Deleting Your Account: You can delete your account through your Profile settings. Click "Delete Account" and confirm the request. We will process the request within a month, or sooner, if possible, but may need to verify your identity. Users are aware that in some cases, we are required by law to retain certain data (e.g., for KYC or payment transaction purposes) even after you request deletion or object to processing.
Data Transfer & International Data Transfer
Services by Bropanda is available internationally. This means your data may be processed in countries with privacy regulations that may be less strict than those in your home country. However, we will always strive to handle Personal Information according to the privacy standards of the country where your data was initially collected. By providing us with your personal information, you consent to its transfer, storage, and processing in countries outside your own, including, but not limited to, the United States. For further details on how we apply privacy principles across different jurisdictions, you can reach out to us at support@esimmroam.com.
Security
We follow industry-standard practices to help protect your personal information. However, no method of online transmission or electronic storage is entirely secure. While we take steps to safeguard your data with physical, electronic, and procedural protections, we cannot guarantee complete security.
It is also the responsibility of Bropanda users to keep their passwords and credentials secure. If you believe your account's security has been compromised, please contact us immediately at support@esimmroam.com.
CHILDREN
Bropanda understands the importance of safeguarding the Personal Data of children. Children under the age of 13 years old are prohibited from using Bropanda's Services. We do not knowingly collect (or knowingly allow any third party to collect) Personal Data from unemancipated minors under age 18, without parental consent. If we become aware that Personal Data has been collected from a person in that category, we will delete the Personal Data and terminate that individual's account as quickly as possible.
SINGAPORE PRIVACY RIGHTS - FOR SINGAPORE RESIDENTS ONLY
Singapore residents have additional privacy rights under the Personal Data Protection Act 2012 ("PDPA"), which grants individuals greater control over their personal data, including how it is collected, used, disclosed, and shared.
Rights Under the PDPA
Under the PDPA, Singapore residents have the following rights:
Right to Access: You have the right to request access to your personal data held by us and obtain information about how it is being processed.
Right to Correction: You may request the correction of any inaccurate personal data that we hold about you.
Right to Withdraw Consent: You have the right to withdraw your consent for us to process your personal data at any time, subject to legal obligations.
Right to Data Portability (Applicable for specific circumstances): You may request the transfer of your personal data to another organization in a structured, commonly used, and machine-readable format, where applicable.
Exercising Your Rights To exercise any of these rights, please contact us at support@esimmroam.com. We may need to verify your identity before processing your request. Depending on the nature of your request, additional verification information may be required.
Bropanda'S CONTACT INFORMATION
We can be contacted through our email address at support@esimmroam.com for any questions, comments, appeals, or complaints concerning our privacy practices you may have or if you need to access this Privacy Policy in an alternative format or language.