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PRIVACY POLICY

SUMMARY

Below is a summary of some key terms of this Privacy Policy. This summary is for your reference only and does not form part of the Privacy Policy.

We, Getverify LDA listen to our users and we are committed to protecting the principles of privacy and fair use that underpin our values to offer a transparent and secure service. We want you to be confident that your personal data is safe and secure with us. 

This Privacy Policy explains the following:

• how we collect your personal data;
• what personal data we collect;
• how we use your personal data;
• who we share your personal data with;
• what measures we take to keep your personal data safe;
• how long we keep your personal data and;
• the rights and choices you have when it comes to your personal data.

Privacy Policy

Last updated – September 11, 2026

1. Who are we?

Getverify LDA, a company incorporated under the laws of Portugal (referred to herein as “Esim io”, “our”, “we” or “us”), gives utmost importance to your (referred to herein as “User” or “you”) privacy and the protection of your personal data. We prepared this Privacy Policy to inform you on which personal data we collect, how and why we process personal data and how can you practice your rights pertaining to your personal data. It should be read together with our Terms of Service, Cookie Policy and Purchase, Cancellation and Refund Policy. This Policy also covers the optional outbound Calling Services in Annex 1 of our Terms of Service, including the processing of called-party telephone numbers.

2. Data controller

Getverify LDA is the data controller with respect to your personal data we process over website https://esim.io, Esim io mobile application, related features and services, and other linked channels, mobile websites or applications (together “Platform”). You can find our contact details below:

Getverify LDA: Avenida do Infante, no. 50, 9004-521 Funchal, Madeira, Portugal

E-mail: support@esim.io

3. How do we collect personal data?

We may obtain personal data through the websites, mobile applications or other similar devices, channels or applications operated by or on behalf of Esim.io; (a) directly from you; (b) automatically from devices that you use to connect to our Services (as described below) and c) from third party sources (such as Google and Apple).

4. What personal data do we collect?

Esim.io provides applications, content and other digital products and other in-app services and related services over the Platform (“Services”).

We collect personal data about you when you submit your data in the course of registering for and/or using our Services for example we may collect your name surname, username, e-mail address, phone number.

Note that it is your responsibility to check and ensure that all data, content, material or data you provide us is correct, complete, accurate and not misleading.

This Privacy Policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which this Platform may link or otherwise reference (collectively Third Party Services or TPS) that you may access through the Services. We take no responsibility for the content or privacy practices of any TPS. We encourage you to carefully review the privacy policies of any TPS you access. This distinction does not exclude our responsibilities for personal data processed on our behalf by calling, verification or other service providers, or our responsibilities for disclosures to independent controllers.

Data that you may provide voluntarily

Certain parts of our Services may ask you to provide personal data voluntarily. For example, we will ask for certain data in order for you to register for an account with us, to begin using our Services, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:

• ID information and Contact Information : (such as name, surname, and email address, country);
• Purchase Metadata: we do not collect or store payment card details directly. Instead, we may receive limited transaction-related metadata (e.g., transaction ID, purchase timestamp, currency, and status) from third-party platforms such as Apple, Google, Zotlo, Jigle or payment processors to fulfill your purchase and comply with refund requests or fraud prevention requirements;
• Marketing & Analytics: IDFA, Advertising IDs, cookie records, and usage metrics (session duration, screen views);
• Transactional Content: Support and feedback messages, support tickets, attachments or files shared with support;
• Other Information: Any additional personal data voluntarily provided by you through the customer support and feedback messages, data to identify a lost account;
• If you sign up through Google, Apple etc. we get account information from them,
• We may ask you to submit proof of identity and/or address verification information in order to comply with the requirements of compliance and regulations.

We use this data solely for the purposes described above. We will try to explain to you at the point we ask you to provide your personal data which personal data that you are asked to provide, and the reasons why you are asked to provide it.

When using our services, in addition to providing data about yourself by creating a profile during your account creation process, you also provide data when you take certain actions that are intended to be public in nature such as when you sign up for our newsletter, create an account, request more information on our contact us page or respond to a survey or questionnaire.

Data that may be collected automatically

When you use our Services, on the applicable legal basis described in Section 6 and with consent where required by law, we may also collect data automatically from you and/or your device which may be considered personal data under applicable data protection laws, such as:

• Data and analytics about your use of our Services;
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
• Data about your device, such as device name and operating system, browser type and language, operating system information such as version, manufacturer, name, brand and model, Referrer URL, country and mobile network code, device language settings;
• Data we collect with cookies and similar technologies;
• Broad geographic location based on your IP address;
• Data about your use of our Services, such as in application interaction and usage metrics.

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for interest based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple you can opt-out this by disabling “allow tracking” option from privacy settings. On Google Android you can opt-out by choosing “Opt-out of interest based ads”.

Advertising IDs are non-permanent identifiers associated with your device and may constitute personal data under applicable law. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Data about your device refers to data about your device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this data may be collected using cookies and/or similar technologies (such as "SDKs" or software development kits), as explained further below.

Data that we may obtain from third party sources

We may receive personal data about you from third party sources. For example, if you clicked on an advertisement to direct you to one of our Services we may be provided with data from which ad-network and advertising campaign the install originated from.

You may choose to connect to our Services via your iCloud or Gmail account. Exactly what data we receive from your iCloud or Gmail accounts will depend on those privacy settings, but it would typically include your basic public profile data such as:

• your username;
• age range; and
• gender

The data that we may collect from our partners could include;

• Data we receive if you link a third-party tool with our Services (such as Apple or Google);
• Demographic data (such as to determine the location of your IP address);
• Data to fight fraud (such as click fraud in advertising);
• Data from platforms that our Services run on (such as to verify payment); and
• Data for advertising and analytics purposes, so we can optimise the Services we deliver to you.

We do not request or intend to collect any special or sensitive categories of data such as any data on health, race, religion, political opinions, sexual preferences or orientation.

You may opt-out of receiving marketing information at any time: such marketing emails tell you how to opt-out. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you; to process payments you make via the Services; and as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal processes, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Services may be ineffective upon opt-out. You may also: (A) access the data we hold about you at any time via your account or by contacting us directly; (B) update or correct any inaccuracies in your personal data by contacting us; (C) in certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data. You may contact us at support@esim.io anytime for any other questions you may have about your personally identifiable information and our use of it.

Calling Services: data and device permissions

Call records. We process the telephone number you call, the date and time, the connected duration and the call status. These records are associated with your use of Calling Services and stored in the Esim io database to provide call history. They are also processed as necessary to route calls, calculate and reconcile calling charges, respond to billing or support queries and address fraud or abuse, subject to the legal bases and retention limits below.

Microphone and voice transmission. Microphone access enables transmission of your voice during a call. Voice is processed and transmitted through the calling infrastructure to convey the call; we do not make or store audio recordings or transcripts through Calling Services. Denying or withdrawing microphone permission prevents voice transmission.

Optional contacts access. With your permission, the Application may access the contacts stored on your device solely to help you select a person to call. Your address book or contact list remains on your device and is not uploaded to Esim io or disclosed to telecommunications providers merely because you grant contacts access. You may instead enter a telephone number manually. The telephone number you select or enter is transmitted to Esim io and the relevant telecommunications, number and routing providers as necessary to place the call, calculate charges and create the call-history record. You can manage contacts permission in your device settings.

Telephone verification. Where verification is required for fraud prevention or applicable telecommunications requirements, we process the mobile number you submit and the verification outcome through a third-party telephone-verification provider, including VerifyKit, Otp.com where used. We explain the applicable verification requirement when verification is requested. Verification requirements may vary by country. Failure to complete required verification may prevent Calling Services in the affected country. Verification does not assign the verified number to you for Calling Services or make it your caller-identification number.

Android device/telephone state. Where needed and permitted by the device operating system, the Application may request telephone/device-state access to manage device or line status, network quality or audio conflicts with an ordinary mobile call. The permission request explains the purpose. You can manage microphone, contacts and any telephone-state permissions in your device settings.

5. How do we use your personal data?

We may use your personal data: 

1. to enable you to access and use the Services. For example;

   • To create user accounts and profiles;
   • To provide you with the correct versions of our applications; and
   • To send you service related communications including confirmations, technical notices, updates, security alerts, and support or administrative messages
   • to provide the Services
   • to enable transactions with respect to Services
   • to enable you to track your transactions
   • Compatibility, performance, and error analysis

   based on the legal grounds that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and processing is necessary for compliance with a legal obligation to which the controller is subject.

2. to personalise and improve aspects of our Services. For example;

   • To respond to your customer support requests;
   • To receive error messages about any issues you / your device encounters with our Services to enable us to fix bugs and interoperability issues;
   • To detect and prevent illegal activities;
   • To track application installs, for purposes of measuring the effect of our marketing campaigns;
   • To conduct optional user feedback surveys;
   • To remember you next time you visit one of our Services; and
   • Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by us.

3. to communicate with you, including some or all of the following:

   • To provide you with in-app offers and rewards based on your interaction with our Services;
   • To serve you with relevant targeted advertisements;
   • To make you offers to purchase in-app items on discount based on your activity with our application and your purchase history; and
   • To send you marketing communications and/or newsletters if you have subscribed for them about rewards and promotions.
4. for research, such as analysing market trends and customer demographics;
5. to comply with legal obligations, including to prevent and/or detect fraud or provide disclosure to the authorities when required by applicable law.

5.6. Calling-specific purposes

For Calling Services, we use the data described above to connect and convey requested calls, provide call history, calculate and administer applicable charges, including deductions from IO Credits where applicable, address support and billing queries, verify eligible use, prevent fraud and abuse, and meet applicable legal obligations. The general references in this Policy to advertising and analytics do not authorise use of call audio, called numbers, call histories or contact lists for advertising or unrelated profiling.

6. Why do we process your personal data?

We will only collect and use your personal data (as described in section 4) in accordance with data protection laws.  Our grounds for processing your personal data are as follows:

1. Consent – Where necessary we will only collect and process your personal data if you have given your clear and affirmative consent for us to do so.
2. Legitimate Interests – We may use and process some of your personal data where we have sensible and legitimate business grounds for doing so. Under the privacy laws there is a concept of “legitimate interests” as a justification for processing your personal data.  Our legitimate interests for processing your personal data are for us to enable you access and use of our Services, to communicate with you about our Services and to improve our Services.
3. Legal obligations – We may need to process your personal data when we are required to comply with a legal obligation.
4. Performance of the contract - Provided that it is directly related to the establishment or performance of the contract, it is necessary to process the personal data of the parties to the contract - We may need to process your personal data when we provide Services to you or when we communicate with you about the Service. It includes that the receive and administering premium services and packages; and processing personal data to handle payment processes.

6.5. Legal bases for Calling Services

We rely on performance of our contract with the calling user for processing that is necessary to provide and charge for the requested Calling Services. Where permitted, we rely on legitimate interests in securing the service, preventing fraud and resolving disputes, after considering the rights and interests of the individuals concerned. We rely on a legal obligation only where an identified obligation actually applies to the processing in question.

A called person is not automatically a party to our contract with the caller. For that person's number and related data, we assess the applicable legal basis separately, including legitimate interests in enabling the communication requested by the caller and protecting the service, subject to the called person's rights and applicable communications-confidentiality rules. Contract performance with the caller is not treated as consent from the called person.

Specific rules on communications confidentiality and traffic data may restrict processing and retention beyond what a general data-protection legal basis permits. Where consent is legally required, including for optional processing or extended call-history functionality, we obtain the appropriate specific consent before that processing. Device permission is managed separately from acceptance of the Terms and does not by itself authorise unrelated data use. Where we rely on consent, it may be withdrawn at any time without affecting the lawfulness of earlier processing.

7. Who do we share your personal data with?

When you use any of our Services, we may only disclose your personal data to the following parties:

1. to our group companies, third party services providers and partners who provide data processing services to us. For example, to support the delivery of, provide functionality on, or help to enhance the security of our Services, or who otherwise process personal data for purposes that are described in this Privacy Policy or notified to you when we collect your personal data.
2. to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary.
3. to any other person with your consent to the disclosure.
4. your information regarding the payment and payment methods (including payment institutions, disclosed to PSP (payment service provider), payment broker, payment service provider, technical integrator) of the Services, including those located outside of your region, in the performance, development and analysis of the core service we provide under our Terms of Service agreement; and information on payment and payment methods are transferred to our business partners as a third party so that our we, as data controller, can fulfill its legal obligation.

7.5. Calling and verification recipients

We disclose the called number and the technical data necessary to convey the call to telecommunications, number and routing providers, including Three where used and relevant destination networks. Voice is transmitted through the infrastructure needed for the call. Providers of OTP services receive the data necessary for requested telephone verification. Providers acting on our behalf must process data under appropriate contractual instructions and safeguards; a telecommunications or verification provider may instead act as an independent controller for processing whose purposes and means it determines, including its own applicable legal obligations. Those roles do not remove our responsibilities for our own processing and disclosures.

Personal data may be processed by service providers or other recipients outside your country as described in Section 12. Acceptance of the Terms of Service is not treated as blanket consent to international transfers; each transfer must have the legal basis and safeguards required by applicable law.

8. What cookies do we use?

A cookie is a very small text file placed on your computer or device. We and our partners use cookies and similar technologies to provide and personalise our Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of our Services may then not function properly.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is part of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites. Please check our cookie policy for further details.

9. What advertisements do we show on our Services?

The advertisements that you see displayed on our Services are delivered on our behalf by certain third-party advertising companies. No data which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third-party advertisers may place or recognise a unique cookie on your browser. This cookie does not collect personal data about you nor is it linked to any identifiable data about you. By using our Services, you are consenting to the use of these third-party cookies for these purposes.

If you would like to learn more about online advertisements and your choices about how this data may be used by these companies, please find more information here http://www.youronlinechoices.com/uk/your-ad-choices.

10. What steps do we take to keep your personal data safe?

Your personal data’s security is very important to us. This is why, where it’s appropriate, we use HTTPS to help keep data about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the data you disclose to us secure. However, we can't guarantee or warrant the security of any data which you send to us, and you do so at your own risk. This does not exclude our obligations to implement appropriate security measures or any liability or remedy that cannot lawfully be excluded.

11. How long do we keep your personal data?

Unless a longer retention period is required or permitted by law, we will only retain your personal data only for as long as reasonably necessary to fulfil the purposes outlined in this Privacy Policy and for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We will for example periodically de-identify unused user accounts and regularly review our data sets. When you delete your account, the following timeframes will apply to the processing of your data. The calling-specific criteria below govern call traffic and verification data. The general periods for logs, purchase records or subscription records do not authorise retaining call traffic data for longer than permitted by the rules applicable to that data.

• Data about your device, such as device name and operating system, browser type and language, operating system information such as version, manufacturer, name, brand and model, Referrer URL, country and mobile network code, device language settings are retained during the subscription period, then deleted.
• Log records are retained for maximum of 1 year, then anonymized.
• Customer support and feedback records are retained for maximum of 2 years, then anonymized.
• ID information and Contact Information are retained during the subscription period, then anonymized.
• Purchase history, subscription types, and consumable usage records are retained for 3 years for tax and financial audit purposes, then anonymized.
• IP addresses and session logs are retained for 90 days for security auditing, after which they are pseudonymized.
• Upon your request to delete your account, your profile data (name, email) is pseudonymized after 30 days.
• Subscription event logs (audit trails) are kept indefinitely where required for financial auditing and fraud prevention.

Retention of calling and verification data

We currently retain Call History Data (the called number, date and time, connected duration and call status) for up to five (5) years from the relevant call for call history, billing and reconciliation, support, fraud and abuse prevention, dispute resolution and applicable legal-compliance purposes. The five-year period is a maximum operational retention period and does not mean that Applicable Law requires all Call History Data to be retained for that period. Where a shorter period is required by Applicable Law or the data is no longer necessary for the applicable purpose, we delete or irreversibly anonymise it earlier; where a specific legal obligation or legal claim requires longer retention, we retain only the data required for that purpose and period. Traffic data that is no longer needed to convey a call or for another permitted purpose is erased or irreversibly anonymised.

Call history is not retained indefinitely merely because it can be displayed in the Application. Keeping records solely for optional history functionality is subject to the applicable traffic-data rules and any required consent. Verification data is retained only as needed for the verification, documented security or fraud-prevention purpose, or an applicable legal requirement. We review the continuing need for retention and delete or irreversibly anonymise data when that need ends.

Deleting an account or changing a device permission does not require erasure of records that must still be retained for a lawful, specific purpose; such retained records remain subject to the applicable access, purpose and retention restrictions. We do not retain call audio recordings or transcripts. You may contact support@esim.io for information about the retention criteria applicable to your call or verification records and to exercise your rights.

12. Do we transfer your personal data outside of the country you are resident?

Our Services are global by nature and your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. We take steps to ensure adequate safeguards are in place to protect your data as explained in our Privacy Policy.

For transfers subject to the GDPR or UK GDPR, we use a legally available transfer mechanism, such as an applicable adequacy decision or approved contractual safeguards, together with any additional measures required for the destination and processing. Where a specific statutory derogation is relied on, its conditions must be satisfied. Merely accepting our Terms does not supply consent for these purposes. You may contact support@esim.io for information on relevant destinations and recipients and a copy or description of applicable safeguards, subject to lawful redactions.

Esim.io is the controller of the personal data for which it determines the purposes and means of processing. Calling and verification providers may act as processors on our behalf or as independent controllers for their own processing, as described in Section 7. International access, storage and routing are subject to Section 12 and applicable data-protection requirements.

It may also be necessary to disclose and transfer some data to third parties in order to ensure optimal 24/7 service fulfillment. All third parties involved have been engaged under a binding confidentiality agreement and have a limited access to Esim.io database for the purposes of providing support.

13. Your personal data rights and how to contact us

You have certain rights under existing data protection legislation including the right to request a copy of the personal data we hold about you, if you request it from us in writing.

1. Your right to learn whether your personal data is being processed and to request information about it if it is;
2. Your right to learn the purpose of processing your personal data and whether they are used in accordance with the purpose;
3. Your right to know the third parties to whom your personal data is transferred, at your resident country or abroad;
4. Right to correct: the right to have your personal data rectified if it is inaccurate or incomplete;
5. Right to erase: the right to request that we delete or remove your personal data from our systems;
6. Your right to request notification of the transactions set forth in the article iv. and v. to third parties to whom personal data has been transferred.
7. Your right to object to the emergence of a result against the person himself by analyzing your processed data exclusively through automated systems; and
8. Your right to demand the compensation of the damage in case your personal data is damaged due to unlawful processing.

To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact us at support@esim.io

The applicable data-protection rights described in this Policy also apply to persons whose numbers are processed because they receive a call, even if they do not hold an Esim io account. Requests may be submitted to support@esim.io, subject to appropriate verification and lawful limitations.

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) Compliance

We do not sell or share Personal Information as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, 'CCPA'). We also do not process Sensitive Personal Information for purposes other than those permitted under the CCPA without your explicit consent. We have not sold or shared Personal Information in the preceding 12 months.

California residents have the following rights under the CCPA:
- Right to Know: Request disclosure of the categories and specific pieces of Personal Information collected, used, disclosed, or shared.
- Right to Delete: Request deletion of Personal Information collected from you, subject to legal exceptions.
- Right to Correct: Request correction of inaccurate Personal Information.
- Right to Opt-Out: Opt-out of sale or sharing of Personal Information.
- Right to Limit: Limit the use and disclosure of Sensitive Personal Information.
- Right to Non-Discrimination: Not be discriminated against for exercising privacy rights.

We will verify all requests as required by law and respond within the statutory period. You may exercise your rights by contacting us atsupport@esim.io

General Data Protection Regulation (GDPR) and UK GDPR Compliance

If you are in the European Economic Area (EEA) or United Kingdom (UK), we process your personal data under the General Data Protection Regulation (GDPR) and UK GDPR based on: consent, contract performance, legal obligations, or our legitimate interests.

Calling Services may involve international routing and recipients in the country of the called number, as well as service providers in other jurisdictions. Hosting a database in the EEA does not, by itself, mean that all related processing and access remain within the EEA. Any transfer outside the EEA or UK must comply with the applicable requirements and safeguards described in Section 12.

You also have the right to lodge a complaint with your supervisory authority if you believe that your personal data has been processed unlawfully.

We do not engage in cross-context behavioral advertising, targeted advertising, or automated decision-making that produces legal or similarly significant effects concerning you. Any profiling we conduct is solely for fraud prevention, service functionality, or compliance purposes, and does not override your legal rights or interests.

Law Enforcement, Government, and Regulatory Requests

We will only disclose personal data to law enforcement, government agencies, or regulatory bodies when: (i) it is necessary to comply with a binding legal obligation; (ii) pursuant to valid legal process; and (iii) proportionate to the request. We will challenge overbroad, unlawful, or inappropriate demands to the fullest extent permitted by law and will maintain a transparency log of such requests unless prohibited.

We retain personal data only as long as necessary for the purposes for which it was collected, including legal, tax, accounting, or reporting obligations. Periodic data minimization reviews are conducted, once data is no longer needed, we securely delete or irreversibly anonymize it.

Where required by applicable law, we will notify the competent supervisory authority of a personal data breach within the applicable statutory deadline. Where a breach is likely to result in a high risk to your rights and freedoms, we will notify affected individuals without undue delay, subject to applicable legal exceptions. Our incident response plan includes containment measures, forensic investigation, and remediation steps to prevent recurrence.

To exercise your rights, and for questions or complaints related to this Policy or the processing of your personal data, we encourage You to contact us at support@esim.io

14. Changes to this Privacy Policy

We may update this Privacy Policy by publishing a revised version with its effective date. We will notify you of material changes before the relevant new processing takes effect and obtain any consent required by applicable law. Continued use or acceptance of the Terms is not, by itself, consent to a new processing purpose or an international transfer.