WHOSE PRIVACY STATEMENT IS THIS?
Cloud Sim and its subsidiaries (hereafter referred to as “Cloud Sim” or “we”) are a group of companies whose parent company is Cloud Sim Telecoms Ltd, a company registered in the UK. Registered number 10075890 and having its registered address at 86-90 Paul Street, London, EC2A 4NE.
The relationship between you and Cloud Sim shall be governed by the laws of the United Kingdom without regard to its conflict of law provisions. You and Cloud Sim agree to submit to the personal and exclusive jurisdiction of the courts located within the United Kingdom.
We may be contacted at firstname.lastname@example.org or in writing to Cloud Sim Telecoms Ltd, 86-90 Paul Street, London, EC2A 4NE.
WHAT KIND OF INFORMATION DOES CLOUD SIM COLLECT?
We may collect personal information about you including, but not limited to the following items.
- Personal information. Examples include – your name, address and phone number as well as email addresses and other information you have provided us with.
- Computer information. Examples include – type of operating system, type of mobile phone, type of computer.
- Historical information. Examples include – how you came to be our customer, referrals and friends, correspondence with our support team or our customer service department or any feedback you have sent.
- Technical information. Examples include – your username and password, IP addresses, calling (and SMS) number and destination, mobile phone service provider, calling (and SMS) history and duration, test calls and SMS made, geolocation to assist in Cloud Sim calling services, any numbers you have preregistered for our services, cookies.
- Products or services information. Examples include -the products or services you use or have attempted to use or the products or services you have ordered and/or had delivered and any associated information with such.
- Marketing-related information. Examples include – products and services we have marketed to you and your responses to these, competitions you may have entered and your entries, links you may have visited on our pages, promotions you have participated in, and opt in or out emails.(Please note: if we have received a request not to send commercial electronic messages to a particular email address we may retain the details and the request indefinitely in order to comply with this request.)
- Legal information. Examples include electronic signatures and electronic agreements to our Terms and Conditions and End User License Agreements (EULA) information we must retain under applicable laws.
WHY DOES CLOUD SIM COLLECT THIS INFORMATION AND HOW DO WE USE THE INFORMATION?
Our primary reason for collecting this information is in order to provide the best possible service to you. Specifically, we collect and use this information to:
- Provide goods and/or services to you;
- Create your account and confirm that your account can be set up;
- Convey communications products on your behalf;
- Market our business to you, provide competitions and similar;
- Arrange for third parties to provide our goods and/or services to you as necessary;
- Manage our financial and commercial relationship with you;
- Verify your identity;
- Enforce fair usage policy and expire bundles;
- Assist with our customer service to you and to resolve any complaints or disputes;
- Manage our business and our technical facilities and to plan future development;
- Disclose to prospective investors in or purchasers of us or our business;
- Protect your and our interests including in particular to enforce any terms or conditions you have agreed to and in to fight against fraud; and
- Comply with any legal requirements;
WHY DOES CLOUD SIM COLLECT THIS INFORMATION AND HOW DO WE USE THE INFORMATION?
Information is normally collected::
- Directly from you;
- From a wholesale supplier or other entity involved in service delivery to you;
- From our computer equipment (eg. Usage details);
- In some cases, from other agencies such as credit reporting agencies;
- From any marketing agencies we may use to market our products and services; or
- If you become our customer as a result of a business acquisition from the vendor.
We hold personal information:
- In paper files
- In computer databases and systems.
All such data is controlled and supervised in accordance with any applicable obligations and exceptions under the relevant legislation. Your information may be accessed by authorised employees or consultants of Cloud Sim or its affiliates that require access in order to fulfill their work-related duties and/or in order to provide the relevant product or service to you. We use such security measures as passwords, user access levels and encryption as well as controlled access places.
CAN YOU ACCESS THE INFORMATION WE HOLD ABOUT YOU?
You may ask for access to information we hold about you. We may charge a reasonable fee for giving access. We may refuse when authorised to do so under the relevant legislation. Some information will not be released except where compelled by law and the appropriate legal procedure.
WHO DO WE DISCLOSE INFORMATION TO?
We may disclose information to the following groups or persons:
- Wholesale suppliers and other entities involved in service delivery to you;
- Other carriers, partner service providers and/or agents in order to provide you with the service or good you have requested;
- Our professional advisers, technical and marketing consultants;
- Another member of the Cloud Sim group;
- Prospective investors in or purchasers of us or our business;
- Our agents and resellers as appropriate;
- Debt recovery agencies or credit reporting agencies in cases of non-payment;
- Fraud checking agencies;
- Payment providers and their affiliates in the case of chargebacks and disputed payments;
- Law enforcement agencies in response to a lawful request;
- Government authorities in response to a lawful request;
- Anyone to whom you complain about us or our services including any disputed payments;
- A person who has claimed a bonus from us for introducing you as a first time customer in so far as we may advise that person that you are a first time customer; and/or
- The administrator of any corporate services or goods provided to a company, group, organization, society or similar.
The information that you hold an account with Cloud Sim will be implicitly disclosed to another, online, connected Cloud Sim user who has your phone number in their address book or contacts list should you download, install and connect with the Cloud Sim product. This is a feature of that particular product.
We may disclose information to respond to legal requirements, to protect our interests or to enforce our policies, protect anyone’s rights, property or safety. We, our local partners, or the operator or company facilitating your communication may provide your information to an appropriate local authority lawfully requesting such information. We will provide all reasonable assistance and information to fulfil this request and you hereby consent to such disclosure.
Where information is released, Cloud Sim will require, where possible, that these third parties take appropriate organisational and technical measures to protect your information and to observe the relevant legislation.
Except for where specified above, Cloud Sim does not disclose, sell, trade or otherwise transfer and information to any third party without your permission except where obliged to do so under applicable laws or by order of competent authorities.
WHAT ARE COOKIES AND CLEAR GIFS AND HOW DOES Cloud Sim USE THEM?
The help option on the toolbar of most browsers can assist you in deleting cookies and in preventing them from being stored on your computer in the future. Should you delete or disable cookies, you may find that some of Cloud Sim’s personalised services are unavailable to you.
Cloud Sim may use clear gifs or web-beacons to count your visits to a particular webpage on its site or in certain emails sent to you. There is no personally identifiable information gathered.
LINKED WEBSITES AND THIRD PARTY APPLICATIONS
If you use any plug-ins, extras or third party applications together with Cloud Sim software and applications then the provider of such may obtain access to information about you. Cloud Sim does not and cannot control how the provider of such services and applications may use any information they obtain about you in connection to your use of the above.
Please ensure you review any privacy policies or other terms and conditions applicable to the use of plug-ins, extras and other applications not provided by Cloud Sim before you install them.
CONTACTING YOU, EMAILS, SURVEYS AND FEEDBACK
We may from time to time ask you to provide information on your experiences with our products and services. You are under no obligation to provide this information and it is on a voluntary basis that you do so.
We may contact you via email, phone or SMS, or through modification of our websites to inform you of faults, changes to services or similar. We may also inform you via any of the above methods of any disputes, violations or suspensions that may occur in relation to your usage of our services, products or those of our affiliates, resellers or agents without limitation.
Cloud Sim may also contact you with specials, promotions, competitions or other similar marketing correspondence. You may opt out of receiving further, non-essential communications by following the opt-out procedure outlined in the communication you receive.
Should you enter a competition, Cloud Sim reserves the right to use any original content you provide as part of the entry requirements to use in future promotional material. This may include your name and country details. You may ask, at the time of entering a competition, to have only your initials released in future promotional materials.
WHAT IF YOU DO NOT PROVIDE THE INFORMATION WE REQUEST?
If you do not provide information we request then it may prejudice our ability and/or willingness to provide or maintain services to you. In some cases it may be a breach of your contract with us.
HOW LONG DO WE KEEP YOUR INFORMATION?
Cloud Sim and its affiliates, agents, and resellers will retain your information for as long as is required in order to meet our obligations under applicable laws and for the purposes of collecting that information as outlined above in the section “Why does Cloud Sim collect this information and how do we use the information?”
Cloud Sim will dispose of your information in a secure manner.