Terms and Conditions

1. Introduction This privacy policy (“Notice”) aims to inform you about the handling of your Personal Data by AHA GRUPA LTD (“SimAbove,” “we,” “us,” or “our”). It outlines the types of personal information (“Personal Data”) that will be collected and processed by SimAbove and/or its third-party service providers when you contact us through our application, website, or when you have contracted our services. This information is provided to you in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) to inform you about your data protection rights.

2. SimAbove as Data Controller For the purposes of this Notice, AHA GRUPA SIA, located at Darzciema 60, Riga, Latvia, LV1073, is the controller of your Personal Data and is responsible for it. SimAbove is committed to respecting your fundamental right to the protection of your Personal Data, and this Notice is intended to inform you about our processing of your Personal Data.

3. Types of Personal Data We Process About You

  • Website Usage and Device Data: When you visit our application or website, we collect data about your interactions, including pages visited, access times and dates, clicks, device information such as IP address, location, device type, language, browser type, and any linked websites accessed through our site. Most of this data is collected via cookies. Please see our Cookies Policy for more information.

  • Customer Data: When you purchase an e-SIM or data plan, we collect your full name, title, country of residence, current location, residential address, network provider, phone number, payment information, email address, device type, and identification documents if necessary, along with other relevant details.

4. Sources of Your Personal Data During our contractual relationship with you or when you visit our website or application, we collect Personal Data either directly from you or indirectly from third parties (e.g., through our affiliates or travel agencies). Cookies and other tracking devices may be used on our website, and your consent is required for non-essential cookies as outlined in our Cookies Policy.

5. Purpose and Legal Basis for Processing Personal Data: We process your Personal Data based on the following legal bases and purposes:

  • Compliance with Legal Obligations: To comply with EU and applicable laws, including law enforcement requests. ◦ Categories of Data: Customer Data, Website Data

  • Performance of a Contract:To provide website access, manage e-SIM or data plan purchases, issue charges, handle customer queries and complaints, manage after-sales services, and manage your registration as a user. ◦ Categories of Data: Customer Data, Website Data

  • Legitimate Interest:To facilitate e-SIM or data plan use, improve our website, tailor products and services, prevent cyber-security issues, streamline business processes, detect fraud or illegal activity, record calls for training, conduct service reviews and satisfaction surveys, and carry out business activities like system testing and quality control.◦ Categories of Data: Customer Data, Website Data

6. Sharing of Personal Data We may share your Personal Data with the following recipients as necessary for the specified purposes:

  • Internal Entities: SimAbove departments (e.g., sales, marketing, IT).

  • Telecommunications Service Providers: Providers in relevant jurisdictions.

  • Regulatory Authorities and Law Enforcement: To comply with legal or regulatory obligations.

  • Third-Party Advisors:Professional advisors like consultants and legal advisors.

  • Third-Party Service Providers:External suppliers for administrative, advertising, communication, corporate social responsibility, maintenance, physical security, archiving, storage, destruction, back-office, and IT services.

7. International Data Transfers Personal Data of users in the European Union may be transferred to recipients outside the European Economic Area (“EEA”) in countries with different data protection laws (e.g., Thailand, Colombia). We ensure appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions, are in place for these transfers. For more information, contact us at secure@simabove.com.

8. Your Data Protection Rights

  • Right of Access: equest a copy of your Personal Data.

  • Right to Object: Object to the processing of your Personal Data for legitimate interests.

  • Right to Rectification: Correct inaccurate Personal Data.

  • Right to Erasure: Delete Personal Data in certain circumstances.

  • Right to Restriction of Processing: Restrict processing in specific cases.

  • Right to Data Portability: Receive your Personal Data in a structured, machine-readable format.

  • Right to Lodge a Complaint: Complain to a supervisory authority in your EU Member State.

  • Right to Object to Automated Decision-Making, including Profiling: Object to decisions based solely on automated processing.

9. Data Retention We retain your Personal Data according to Latvian and EU laws and for as long as necessary for the purposes for which it was collected. Retention periods depend on factors such as the length of our relationship, legal obligations, and the necessity for retention in light of legal positions or investigations.

10. Children’s Personal Data We do not knowingly collect Personal Data from individuals under 18 years old. If we become aware of such collection, we will delete the data and terminate the account.

11. Contact Information for Data Protection For questions or to exercise your data protection rights, contact our Data Protection Officer at secure@simabove.com or our customer service team at help@simabove.com.

12. Updates to This Notice This Notice will be regularly reviewed and updated as necessary. Updates will be posted on this section of the website. The English version of this Notice prevails in case of conflicts with translated versions.

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