This Privacy Policy applies to the website saysim.io (the "Website") and the eSIM services offered by Soundphonium Limited (the "Company"). By accessing or using our Services, you acknowledge that you have read and understood this Policy.

1. Definitions

  • Company / We / Us: Soundphonium Limited.

  • User / Customer / You: Anyone accessing or using the Services.

  • Services: Sale, activation, and management of prepaid data‑only eSIM plans.

  • Personal Data: Any information that identifies a User.

  • eSIM Data: Technical data required to activate an eSIM plan (ICCID, EID, IMEI, etc.).

  • Telecom Partners: Third‑party carriers or connectivity providers who activate eSIM plans.

2. Personal Data We Collect

We collect only data required to perform the Services and operate the Website, and we do so in compliance with UK GDPR and GDPR principles.

2.1 Data provided by the User: We collect information when Users register, create an order, request support, or activate an eSIM. This includes:

  • Full name and date of birth (used for account identification and fraud prevention)

  • Email address (used for account access, activation details, and essential service communication)

  • Phone number (used for verification or service confirmation when required)

  • Physical address (used for account verification, billing, or compliance purposes)

  • Payment information (payment confirmation only; card details are stored by payment processors NOT by the Company)

  • eSIM activation identifiers (EID / IMEI / ICCID) when required by Telecom Partners to activate the plan

2.2 Data collected automatically: We collect technical data through cookies and analytics tools when Users access the Website. This includes:

  • IP address and approximate location (for fraud prevention and security)

  • Browser/device information (to optimize compatibility and performance)

  • Access timestamps and session activity (used to improve support and diagnose issues)

This information helps us ensure the Website functions reliably, efficiently, and securely.

3. Purpose of Data Processing

We process Personal Data only where necessary to:

  • Create and manage User accounts and verify identity

  • Process orders and enable secure payment handling

  • Activate eSIM plans through Telecom Partners

  • Provide customer support, troubleshooting, refund evaluation, and technical assistance

  • Improve Website performance, analytics, and reliability

  • Detect and prevent fraudulent or abusive activity (e.g., automated attacks, chargebacks)

  • Fulfill legal and regulatory requirements related to telecommunications and bookkeeping

We do not use Personal Data for profiling or automated decision-making unrelated to service delivery.

4. Data Sharing and Disclosure

We only share data when required to deliver the purchased service. We do not sell or rent Personal Data.

Data may be shared with:

  • Telecom Partners: only the minimum data is shared to activate eSIM (e.g., ICCID, EID, IMEI)

  • Payment processors: for secure payment handling

  • Hosting and technical providers: to operate Website infrastructure

  • Fraud prevention and cybersecurity tools: to prevent payment abuse and unauthorized access

  • Regulators or legal authorities: only if required by law or lawful request

All third parties are contractually bound to confidentiality and must process data only according to our instructions.

5. International Transfers

Because eSIM activation may involve telecom carriers located outside the UK/EU, data may be transferred internationally. We ensure protection through:

  • Standard contractual clauses (SCCs)

  • Adequacy decisions (where applicable)

  • Provider contractual guarantees and security standards

Transfers occur only when strictly required for activation or lawful obligations.

6. Data Retention

Type of Data Retention Period
Account & order information Up to 24 months from last activity
eSIM activation identifiers Only as long as required for activation & regulatory purposes
Transaction records 6 years (legal and accounting obligations)
Support communication Up to 12 months

After expiration, data is permanently deleted or anonymized.

7. Legal Basis (GDPR / UK GDPR)

The Company processes data under the following legal grounds:

  • Contract performance (order processing and eSIM activation)

  • Legitimate interest (fraud prevention, service improvement)

  • Legal obligation (financial record retention requirements)

  • User consent (optional marketing communication)

Users may withdraw consent at any time.

8. User Rights

Users have full control over their Personal Data and may request, at any time:

  • Correction of inaccurate or incomplete data

  • Deletion of data (where no legal retention obligation applies)

  • Export or transfer of their Personal Data (data portability)

  • Withdrawal of marketing consent without affecting service use

Requests may be submitted via queries@saysim.io.

9. Security Measures

We apply industry‑standard safeguards:

  • Encrypted transmission (HTTPS/SSL)

  • Secure storage and limited access

  • No card details stored on our servers

Users are responsible for keeping login information secure.

10. Age Restriction

The Services are available only to Users 18 years or older. We do not knowingly collect data from minors.

11. Cookies and Tracking

The Website may use cookies and similar technologies (such as pixels or local storage) to enhance User experience, provide core functionality, and protect the Website from fraud or misuse.

Cookies may be placed by the Company (first-party cookies) or by trusted third parties (third-party cookies such as analytics or payment security tools).

We use the following types of cookies:

  • Strictly Necessary Cookies: Required for the Website and account login to function. Without these cookies, certain features (such as checkout or secure login) cannot operate.

  • Performance & Analytics Cookies: Used to understand how Users interact with the Website, which helps us improve reliability and usability. We may use analytics tools to collect anonymized traffic statistics. These cookies are optional.

  • Security & Fraud Prevention Cookies: Used to detect abusive or fraudulent activity, prevent unauthorized access, and ensure safe payment processing.

How Users Can Manage Cookies: Users may restrict or remove cookies at any time through their browser settings. Most browsers allow Users to:

  • block or delete cookies,

  • disable tracking technologies,

  • restrict third-party cookie placement.

If Users disable cookies, certain features (including account login or checkout) may become unavailable or may not function correctly.

The Company does not use cookies for targeted advertising or behavioral profiling.

12. Changes to This Policy

We may update this Privacy Policy when necessary. Updated versions will be posted on the Website. Continued use of the Service constitutes acceptance of the updated Policy.

13. Contact

For data and privacy inquiries:

Soundphonium Limited

Email: queries@saysim.io
Registered Address:
Office 6364, 58 Peregrine Road, Hainault, Ilford, Essex, United Kingdom, IG6 3SZ