This Privacy Policy (“Policy”) describes how Fx Technology LTD (“Fx Technology LTD”, “we”, “us”, or “our”) collects, uses, stores, and protects personal information when you access or use Unbound (the “Platform”) and its related services (the “Services”).

By using our Platform or Services, you acknowledge that you have read and understood this Policy.

1. Who We Are

Fx Technology LTD provides global eSIM connectivity services through the Unbound marketplace.
We act as a data controller for personal information processed in connection with your use of the Platform and Services.

Contact information:
hello@unboundsim.com

2. Information We Collect

We collect only the minimum amount of data necessary to provide our Services, comply with legal obligations, and process payments.

We may collect the following types of information:

2.1 Information You Provide to Us

Account & Contact Information (if an account is created)

• Email address
• Password (encrypted and not visible to us)
• Country (optional)

Customer Support Information

• Email address
• Support ticket details
• Error logs or screenshots you voluntarily provide

2.2 Automatically Collected Information

When you access our Platform, we may collect:

• Device information (model, OS, browser type)
• IP address (for security and fraud prevention)
• General location (country level only)
• Cookies and similar technologies (see Section 10)

We do not collect or track:

• Browsing history
• Call/SMS logs
• User activity logs
• Real-time location beyond what is technically necessary for service delivery or fraud prevention

2.3 Information Necessary for eSIM Delivery

To issue and activate eSIMs, we may process:

• Device eSIM identifiers (EID)
• Activation status
• Country or region of intended use

No KYC identity documentation is required unless legally mandated.

2.4 Payment Information

When you make a purchase via Stripe:

• We do not store your full card number or CVV.
• Stripe collects and processes payment information directly on our behalf.
• Stripe may collect:
  
  • Cardholder name
  • Billing address
  • Card details
  • Email address
  • Fraud-prevention signals (IP address, device metadata)

You can access Stripe’s privacy policy here:
https://stripe.com/privacy

For crypto payments, we collect only the wallet address and transaction ID required for transaction verification.

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Delivery

• Providing eSIM connectivity
• Activating and managing eSIM profiles
• Delivering purchased Services
• Ensuring functionality of the Platform

3.2 Payment Processing

• Processing payments via Stripe or crypto gateways
• Fraud detection and prevention
• Chargeback and dispute management

3.3 Customer Support

• Responding to support requests
• Troubleshooting eSIM activation issues

3.4 Legal & Compliance

• Complying with tax, accounting, and telecom regulations
• Responding to lawful requests from regulators or law enforcement

We do not use your data for:

• Advertising
• User profiling
• Selling your data to third parties

4. Legal Bases for Processing

Where applicable, we process personal data under the following legal bases:

• Contractual necessity
  To provide and maintain our Services and process purchases.
• Legitimate interests
  Fraud prevention, security, analytics, service optimization.
• Legal obligation
  Compliance with tax laws, financial regulations, or lawful government requests.
• Consent
  Only where explicitly required (e.g., for cookie tracking beyond essential operations).

5. How We Share Information

We do not sell or rent your personal information.

We may share your data only with the following authorized parties:

5.1 Service Providers

• Stripe (payment processing)
• Cloud hosting providers
• Customer support tools
• Fraud-prevention services

All such providers are bound by confidentiality and data protection obligations.

5.2 Telecom Operators & Connectivity Providers

For the purpose of delivering and activating eSIMs, we may share:

• Device EID
• eSIM activation status
• Country of intended use

No personal identity data is shared unless legally required by regulation.

5.3 Legal Compliance

We may disclose information if required by:

• Law, court order, or regulatory authority
• To protect our rights, users, or systems
• To investigate fraud or misuse

We do not voluntarily share user data with governments unless legally compelled.

6. International Data Transfers

We may store or process your data in countries outside your residence.

When we transfer data internationally, we use safeguards such as:

• Standard Contractual Clauses (SCCs)
• GDPR-approved mechanisms
• Secure encryption

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy or as required by law.

Typical retention periods:

• Account information: while your account remains active
• eSIM activation records: up to 12–24 months
• Transaction records: up to 7 years (legal accounting requirement)
• Support tickets: up to 24 months

We delete or anonymize data once retention periods expire.

8. Your Rights

If you are located in the UK, EU, or another region with data protection rights, you may have the right to:

• Access your data
• Request correction
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to certain processing
• Port your data
• Withdraw consent (where applicable)

You can exercise these rights by contacting us at:
📧 hello@unboundsim.com

We will respond within applicable legal timeframes.

9. Security Measures

We take data protection seriously and use:

• Encrypted data transmission (TLS)
• Encrypted storage for sensitive data
• Access control and authentication
• Firewall and attack prevention systems
• Stripe-certified PCI-DSS–compliant payment handling

No online service is 100% secure, but we continuously work to protect your data.

10. Cookies & Tracking Technologies

We use cookies only for:

• Essential platform functionality
• Authentication
• Security & fraud prevention
• Basic analytics (non-identifiable)

We do not use cookies for advertising or cross-site tracking.

You may manage cookie preferences through your browser settings.

11. Children’s Privacy

Our Services are not intended for children under 18.
We do not knowingly collect personal data from minors.

If you believe a minor has provided data improperly, contact us to request deletion.

12. Changes to This Policy

We may update this Policy from time to time.
When we do, we will revise the “Last updated” date above.

Material changes will be communicated via the Platform or email notifications.

13. Contact Us

For privacy inquiries, data access requests, or concerns, contact:

hello@unboundsim.com

Fx Technology LTD (2 Stone Buildings, London WC2A 3TH)

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