Privacy Policy

 

Effective Date: January 25, 2026

ESIMAX LINKTECH LIMITED, operating under Esimvanta (www.esimvanta.com) ("Esimvanta", "we", or "our"), recognizes the importance of your privacy. This Privacy Policy describes how we collect, use, share, and protect your personal information (also known as personal data). This Privacy Policy also outlines your rights and choices regarding personal information, as well as how to contact us for answers to your questions.

By registering an account or otherwise using or accessing any Esimvanta website, application, product, software, tool, data source, and/or service (collectively referred to as the "Services"), you signify that you understand and agree to the terms of this Policy.

This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information. Please read this Privacy Policy carefully.


Table of Contents

1. Applicability of this Privacy Policy

2. How We Collect, Disclose, and Use Personal Information

3. Information We Collect

4. Data Retention

5. How We Use Information

6. How We Share Personal Information

7. Your Rights

8. Data transfer and international data transfer

9. Security

10. Changes to this Policy

11. Children

12. Contact Information

13. Additional Information for California Residents


1. Applicability of this Privacy Policy

This Privacy Policy applies to all users of Esimvanta worldwide, regardless of whether you are located in the US or other countries or regions. In particular, if you are a resident of Virginia, California, Colorado, Connecticut, or Utah, the privacy rights described in this policy also apply to you. This policy covers all service channels of Esimvanta, including mobile applications, partner platforms, websites, features, etc.

This Privacy Policy describes how Esimvanta collects and uses data, and applies to all Esimvanta users worldwide, unless the services used by users are covered by a separate privacy statement.

This Privacy Policy specifically applies to:

End User: An individual who directly uses and interacts with the service through an Esimvanta account for personal purposes.


2. How We Collect, Disclose, and Use Personal Information

We will collect your information through various means, and the specific methods depend on how you interact with us and our services, including:

(1) Information collected directly from you

We collect information directly from you that you provide to us, such as when you register an account, sign up to receive our communications, place an order, make a purchase, or contact us by phone, email, chat, or other means.

(2) Information collected automatically when you use our website and services

When you use our website and services, we may automatically collect certain information through technologies such as cookies, pixels, web beacons, server logs, etc., such as IP address, browser type, language used, access date and time, operating system and version, device identifiers, and usage information.

You have the right to disable cookies or set privacy preferences through your browser settings. Where required by applicable law, we will use non-essential cookies (such as analytics/advertising cookies) only after obtaining user consent. Please note that disabling certain cookies may affect certain functions of the website and services.

(3) Information collected from other sources

We may collect your information from other sources, including our affiliated companies, business partners, service providers, online social media networks, and other third parties, or from publicly available sources, where permitted by law. For example, if you submit a job application or become an employee, we may conduct a background check where permitted.

Esimvanta classifies data and information systems based on legal requirements, sensitivity, and business criticality to ensure appropriate protection of information. A "data controller" is an entity that determines the purposes and means of data processing.


3. Esimvanta as the data controller

Esimvanta acts as a data controller when determining the purposes and means of processing personal data. As a data controller, Esimvanta is responsible for ensuring that personal data is processed in accordance with applicable data protection laws. The activities carried out by Esimvanta as a data controller include:

Direct Registration

When a user directly registers with the service, Esimvanta acts as the data controller. This applies to: End users who directly register with the Esimvanta service.

Main Activities

(1) Service Delivery: Use data to provide Esimvanta products and services.

(2) Anti-Fraud: Monitor and detect fraudulent transactions and activities.

(3) Legal Compliance: Comply with applicable financial, legal, and regulatory obligations.

(4) Service Enhancement: Develop and improve products and services based on data analysis.


4. Information We Collect

The following table illustrates the types of information we collect in various scenarios and how we use this information.

Scenario: Account Registration

Data Types: We will collect your name and contact information, including email, when you create an account. We will also collect information related to the actions you perform when logging into your account.
Primary purposes: Provide account features, facilitate checkout, save preferences and transaction history, and fulfill the contract we have entered into with you.

Scenario: Necessary Online Tracking Technology

Data Types: We use Cookies and transparent GIFs. A "Cookie" is a small piece of information that a website sends to a computer's hard drive when a user browses the website. A transparent GIF refers to a pixel that a browser loads when you visit a website. These tracking technologies may collect information such as your browser type, operating system, IP address, domain name, click activity, referring website, and/or the date/timestamp of the visitor.
Primary purpose: Ensure the efficient and secure operation of our website.

Scenario: Non-essential tracking technology

Data Types: We may use tracking technologies (such as cookies or pixels) on our website to collect analytical data, record how you interact with our website, measure advertising performance, or (where permitted) allow us to participate in behavioral advertising. These technologies may collect information such as your browser type, operating system, IP address, domain name, click activity, referring website, and/or timestamps. We or third parties may also collect information at different times and on different websites to measure ads or serve ads.
Main purpose: In accordance with legal requirements, we will use third-party cookies and similar technologies after obtaining user consent where required. You may manage cookies via browser settings and, where available, cookie consent tools on our site.

Scenario: Audience Characteristic Information

Data Type: We may collect information such as approximate location (for example, derived from IP address), language preference, or general preferences.
Primary purpose: Understand users and provide localized or customized service experiences.

Scenario: Feedback/Support

Data Type: If you provide feedback or contact us for support, we will collect your name and email address, as well as any content you send to us, in order to respond to you.
Primary purpose: Provide customer support and resolve issues.

Scenario: Mobile Devices

Data Types: We may collect information from your mobile device, such as device identifiers, operating system version, and related technical signals when accessing our website or services.
Primary purpose: Security, fraud prevention, and service reliability.

Scenario: Place an Order

Data Types: We may collect your name, billing address, email address, phone number, and payment-related details necessary to process transactions. Payment card information is typically processed by payment service providers.
Primary purpose: Fulfill services, process payments, provide support, and comply with legal obligations.

Scenario: Partner Promotion

Data Type: We may collect information you provide during co-branded promotional activities with other companies.
Primary purpose: Complete promotional activities and fulfill related requests.

Scenario: Investigation (Surveys)

Data Type: When you participate in a survey, we collect the information you provide through the survey. If the survey is provided by a third-party service provider, the third party's Privacy Policy applies.
Primary purpose: Understand opinions and improve services.


5. Data Retention

We retain your personal information only for as long as necessary to achieve the purposes outlined in this Privacy Policy (including purposes to meet any legal, accounting, or reporting requirements), unless the law requires or permits a longer retention period. To determine the appropriate retention period for personal information, we consider the quantity, nature, and sensitivity of the information, the risk of harm from unauthorized use or disclosure, the purpose for which we obtained the information, whether we can achieve those purposes by other means, and applicable legal requirements.


6. How We Use Personal Information

In addition to the above purposes and uses, we will also use information in the following ways:

(1) Identify you when you visit our website.

(2) Provide products and services or process returns/refunds where applicable.

(3) Improve our services and products.

(4) Simplify the checkout process.

(5) Analyze user preferences to improve our products and services.

(6) Communicate with you, such as responding to requests, inquiries, questions, or feedback.

(7) Send marketing and promotional materials related to our products/services/sales/promotions (where permitted and/or with your consent where required).

(8) Detect and prevent malicious, deceptive, fraudulent, or illegal activities, including violations of our policies, terms and conditions, security incidents, and harm to rights, property, or safety.

(9) Debug, identify, and fix errors that may compromise expected functionality.

(10) Fulfill legal or regulatory obligations, establish or exercise our rights, and defend against legal claims.

(11) Internal management and relationship management.

(12) Other purposes that you may agree to from time to time.

We process your information based on your consent (where required), our need to fulfill contracts, our legal obligations, and/or our legitimate interests in conducting business.


7. How We Share Personal Information

In addition to specific circumstances discussed in other parts of this Privacy Policy, we may disclose personal information in the following situations:

Affiliated Companies and Acquiring Companies

We may share information with our affiliated companies (such as parent companies, sister companies, subsidiaries, joint ventures, or other commonly controlled companies). If another company acquires or plans to acquire our company, business, or assets, we may also share information with that company, including during the negotiation stage.

Other disclosures without your consent

We may disclose information in response to subpoenas, warrants, or court orders, or requests related to any legal proceedings, or to comply with relevant laws. We may also share your information to establish or exercise our rights, defend against legal claims, investigate or prevent suspected illegal activities, suspected fraud, personal or property safety, or violations of our policies, or take corresponding actions.

Partner Promotions

We may offer promotions in conjunction with third-party partners. If you decide to participate in a promotion sponsored by a third-party partner, the information you provide will be shared with us and the third-party partner. The use of your information by the third-party partner is not governed by this Privacy Policy.

Service Providers

We may share your information with service providers to help manage our website, provide services, ensure effective operation, provide technical support, process payments, and assist in fulfilling orders.

Other disclosures with your consent

With your consent or instruction, we may disclose your information to other third parties.

Advertising Partners

To measure advertising performance and (where permitted) deliver personalized ads, we may share limited identifiers or de-identified/aggregated information with advertisers, ad networks, and data aggregation platforms. We do not share your identity information in a way that is inconsistent with applicable law. You can manage cookies and certain advertising preferences via browser settings and, where available, cookie consent tools on our site.

Selling Personal Information

We will not sell your personal information to any third party for profit.


8. Your Rights

Depending on your location and applicable laws, you may have the following rights:

Access to Your Data: Request that we disclose personal information related to you that we have collected, used, or disclosed, and information related to our data practices. In certain limited circumstances, you may request access to your personal information in a portable, machine-readable format.

Verify and Request Correction: Request correction of inaccurate personal information. You may update certain information in your account profile; otherwise you may contact us.

Delete your personal information: Request deletion of personal information we have collected about you, subject to legal exceptions.

Withdraw your consent: If processing is based on consent, you may withdraw consent at any time.

Right to object: Where applicable, object to processing of your personal information for certain purposes (such as direct marketing).

Online Tracking: We currently cannot recognize the "Do Not Track" directive.

As a resident of California, Virginia, Colorado, Connecticut, or Utah in the US, you may also have rights under relevant state laws (such as CCPA, VCDPA, CPA, CTDPA, UCPA, etc.), including:

(1) Right to be informed

(2) Right to deletion

(3) Right to correction

(4) Right of access

(5) Right to opt out of sale or sharing (as defined by law)

(6) Right to be free from discrimination

(7) Use an authorized agent

(8) Right to data portability

(9) Rights regarding sensitive data (as applicable)

(10) Right of objection for certain purposes (such as direct marketing, targeted advertising)

To submit a request to exercise any of the above rights or to appeal a decision we have made in relation to a data subject’s rights request, please email support@esimvanta.com.

We may ask you to verify your identity. Depending on your request, we may ask for information such as your name, the last item you purchased from us, or the date of your last purchase. We may also ask you to provide a signed statement to confirm your identity.

How can I delete my account?

You can delete your account using the "Delete Account" feature in Profile Settings. Please log in to your account, then navigate to Profile Settings. Click the "Delete Account" button and confirm the operation. We will generally process the request within 7 days, and if special requirements are attached, we will process it within one month of receiving the request.

Please note that under any circumstances, we may need to verify your identity and your relationship with us before proceeding with your request.

Under what circumstances will Esimvanta continue to process data after receiving a deletion request or an objection to processing request?

In certain circumstances, even after receiving a deletion request or an objection to processing request, Esimvanta may retain and process your personal data as required by law (for example, retaining transaction records to comply with legal obligations).


9. Data transfer and international data transfer

The service is operated under Esimvanta and can be accessed in Europe and abroad. Therefore, your information may be processed in other countries/regions where privacy laws may not be as strict as those in your home country. Nevertheless, we will take reasonable measures to process personal information in accordance with applicable privacy principles. By submitting your personal information to us, you consent to the transfer, storage, and processing of your information in countries/regions outside your country of residence, including but not necessarily limited to the US, where permitted by law.

International data transfer safeguards (especially for users in the European Union and Brazil)

To safeguard the security of your personal data, we may implement appropriate technical and organizational measures, including where applicable:

(1) Use of the Standard Contractual Clauses (SCCs) approved by the European Commission as a legal basis for data transfer

(2) Measures intended to align processing with GDPR/LGPD principles where required

(3) Evaluations of data transfers to ensure safeguards are appropriate

If you would like to learn more about our efforts, you may send an email to support@esimvanta.com at any time.


10. Security

We follow recognized industry standards to help protect your personal information. No method of Internet transmission or electronic storage is completely secure. Therefore, although we strive to implement physical, electronic, and procedural safeguards to protect the confidentiality of information collected online, we cannot guarantee its absolute security.

Users remain responsible for ensuring the security of their passwords and credentials. If you believe your interaction with us is no longer secure (for example, if you feel the security of your account has been compromised), please immediately email support@esimvanta.com.


11. Changes to this Policy

We may update this Privacy Policy from time to time. In the event of any material changes, we will post a notice on this page and notify you via email, in-app notification, pop-up window, or other reasonable means. The changes will take effect from the date of publication. If you continue to use our services after the changes come into effect, it means you accept being bound by the revised policy. We encourage you to review the latest version each time you visit our website or application.


12. Children

Our services are not provided to children under 13 years of age, and we will not intentionally collect personal information from minors under 16 years of age without parental consent where required. Children under 13 years of age should not provide personal information to us.


13. Contact Information

If you have any questions, comments, grievances, or complaints about our privacy practices, or if you need to access this Privacy Policy in an alternative format due to a physical disability, please contact us:

Email: support@esimvanta.com
Tel: +852 53256937
Company Name: ESIMAX LINKTECH LIMITED
Company Address: Room D07, 8th Floor, Kai Tak Building, 99 Fu Wang Street, Hong Kong (This is a non-return address)
Working Hours: Monday to Friday, 9:30 a.m. – 6:00 p.m. (Hong Kong Time)

If you are not satisfied with our response and you are located within the European Union or the United Kingdom, you have the right to lodge a complaint with the local regulatory authority.


14. Additional Information for California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a resident of California, in addition to the other provisions of this Privacy Policy, the following privacy disclosures also apply to you.

California Anti-Customer Information Disclosure Act

If you would like to learn in detail about the categories of personal information (if any) that we share with third parties or affiliated companies for their use in direct marketing, please submit a written request to us using the information in the "Contact Information" section above.

Collection Notice

The following describes the categories of personal information we collect, disclose for business purposes, “sell,” and/or “share” (as those terms are defined by California law). Please note that we may also disclose any category of personal information we collect to government entities to meet legal requirements or prevent illegal activities.

We do not “sell” your personal information for profit. As described elsewhere in this Privacy Policy, we may use cookies and similar tracking technologies to deliver targeted advertising where permitted. You can manage cookies through browser settings and, where available, cookie consent tools on our site.

Important note on sensitive data: We do not collect sensitive identifiers unless necessary for providing services, fraud prevention, complying with law, or where required by a network operator for identity verification in certain jurisdictions.

Categories / Recipients

Personal Information Category: Identification Information
May include real name, alias, postal address, unique personal identification information, online identifiers, email address, account name, or similar identifiers.
Recipient Category: Affiliate or Subsidiary, Business Partner, Data Analysis Provider, Internet Service Provider, Co-Marketing Partner, Operating System and Platform, Other Service Provider, Payment Processor and Financial Institution, Professional Service Organization (which may include audit firms and law firms), Social Network, AD Network.

Personal Information Category: Government-issued Identification Information (if required)
May include driver’s license number, state-issued ID number, or passport number, only where required for identity verification or regulatory compliance (for example, operator eKYC in certain jurisdictions).
Recipient Category: Network Operator (Operator Requiring eKYC), Professional Service Organization (which may include audit firms and law firms).

Personal Information Category: Financial Information
May include payment-related information necessary to process transactions (generally handled by payment processors/financial institutions).
Recipient Category: Operating systems and platform payment processors, financial institutions, professional service organizations (which may include audit firms and law firms).

Personal Information Categories: Characteristics of Protected Classes (if provided/required)
May include age or other characteristics only where applicable and lawful.
Recipient Category: Network Operator (Operator Requiring eKYC), Professional Service Organization (which may include audit firms and law firms).

Personal Information Category: Business Information
May include products or services purchased, acquired, or considered for purchase, or other purchase or consumption history or tendencies.
Recipient Category: Affiliated Company or Subsidiary, Business Partner, Data Analysis Provider, Internet Service Provider, Joint Marketing Partner, Operating System and Platform, Other Service Provider, Payment Processor and Financial Institution, Professional Service Organization (which may include audit firms and law firms), Social Network.

Personal Information Category: Internet or other electronic network activity information
May include browsing history, interaction with websites/applications/advertisements.
Recipient Category: Data Analysis Provider, AD Network.

Personal Information Category: Professional or Employment-Related Information (if applicable)
Recipient Category: Affiliated Companies or Subsidiaries, Business Partners, Operating Systems and Platforms, Other Service Providers, Professional Service Organizations (which may include audit firms and law firms).

Personal Information Category: Non-Public Education Information (if applicable)
Recipient Category: Affiliated Companies or Subsidiaries, Business Partners, Operating Systems and Platforms, Other Service Providers, Professional Service Organizations (which may include audit firms and law firms).

Personal Information Category: Other categories described in the California Customer Records Statute (as applicable)
May include signatures or other information only where applicable and lawful.
Recipient Category: Network Operator (Operator Requiring eKYC), Professional Service Organization (which may include audit firms and law firms).

California Sensitive Information Disclosure

We may collect certain categories of sensitive personal information (as defined by California law) only as needed to process transactions, comply with laws, manage our business, prevent fraud, or provide services and support. We do not use sensitive personal information for any purpose not permitted by applicable law.


© 2026 ESIMAX LINKTECH LIMITED. All rights reserved.