Privacy Policy

1. Introduction

This privacy policy (“ Notice ”) is intended to inform you about the processing of your Personal Data by Holafly Limited (“ Holafly ”, “ we ”, “ us ” or “ our ”) and also sets out the information, including the personal information set out below, relating to you or provided by you to us (“ Personal Data ”). This information will be collected and processed by Holafly and/or on its behalf by its third party service providers when you contact us through our channels, such as our App or Website, after you have engaged our services. We are required to provide you with this information, as well as to inform you of your data protection rights, under the General Data Protection Regulation (EU) 2016/679 (“ GDPR ”).

2. Holafly as data controller

For the purposes of this Notice, the controller of your personal data is Holafly Limited, located at 2 Grand Canal Square, 6th Floor, Dublin 2, D02 A342, Ireland. Holafly is the controller of your Personal Data.

Holafly is committed to respecting your fundamental right to the protection of your Personal Data and this Notice is intended to inform you about our treatment of your Personal Data.

3. Types of Personal Data we process about you

Category of Personal Data Information
Website usage and device data: When you visit our app or website.
  • Your visits and interactions with our website, including the pages you view, the time and date you access them, what you click on, and when you take these actions;
  • your device data, including your IP address, location data, device type and language, browser type and other related information; and
  • any associated website that you access through our website.
Most of this Personal Data is collected through the use of cookies on the website. Please visit our Cookie Policy for more information about how the website uses cookies.
Customer data: When you purchase an e-SIM or data plan.
  • Full name, title, country of residence, current location, address, network provider, phone number, payment information, email address, device type (e.g. brand and model), copy of your passport, driver's license or similar identification document (where required) and other information relating to you when you interact with us in relation to the purchase of an e-SIM.

4. Sources of your Personal Data

During the course of our contractual relationship or when you visit our website or application, we will collect your Personal Data in different ways: (1) directly from you, (2) indirectly from third parties (for example, through our affiliates or travel agencies once you have contracted our services).

  • When you browse our website, different cookies and other tracking tools may be installed on your device, as explained in our Privacy Policy. Cookie Policy . Where we collect your Personal Data through the use of cookies on our website that are not necessary for its functioning, we will ask for your prior consent to do so.

5. For what purpose and on what legal basis do we process personal data?

In the table below we set out the key context under which (“ Legal Basis ”) we process your Personal Data. We also explain how (“ Nature of Processing ”) we obtain and collect your Personal Data.

Legal basis Nature of the treatment and purpose Category of Personal Data
Compliance with legal obligation
  • Holafly may process your Personal Data where necessary to comply with legal obligations to which we are subject under the European Union and/or applicable laws, including, but not limited to, safeguarding and complying with law enforcement requests.
Customer Data: Website Data
Execution of a contract
  • Provide you with access to and use of the website.
  • Manage the purchase of the e-SIM or data plan that we sell on our website and the payment related to said products.
  • Calculate and issue charges for services provided to you.
  • Review and respond to customer incidents, queries, complaints or requests in relation to our products and services.
  • Manage and carry out any type of after-sales service.
  • Manage your registration as a user on our website and/or application, as well as allow you to access the private user area of ​​Holafly.
Customer data Website data
Legitimate interest
  • Facilitate the use of your e-SIM or data plan, including managing your account and providing you with customer service.
  • To better understand how our customers use our website so we can improve it. To personalize products and services for you and, if you consent to direct marketing, to personalize direct marketing.
  • Control and prevent cybersecurity problems and unauthorized use of our information, systems and/or computer equipment.
  • Streamline our business processes by using external platforms.
  • Conduct internal business reviews and, if necessary, contact the customer in the event that fraud or identity theft is detected or there is reasonable suspicion of fraud, identity theft or illegal activities.
  • Record calls for training purposes and to improve our customer service.
  • Carry out any other activities necessary for the development of our business, including system testing, network monitoring, staff training and quality control.
    •
    Customer Data: Website Data

    6. With whom do we share your Personal Data?

    Depending on the purposes for which we process your Personal Data, we may share it, to the extent necessary, with some or all of the following recipients:

    • Holafly internal/intragroup entities: internal departments and services (such as our Sales Department, Marketing Department or IT Department).
    • Telecommunications service providers: service providers located in the relevant jurisdiction in which the e-SIM service was purchased.
    • Regulatory authorities and law enforcement agencies: Where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request, including to the Inland Revenue, the Department of Social Protection, the Data Protection Commission, the Employment Relations Commission, the Irish courts, the Garda Síochána or any other applicable authority.
    • External advisors/professionals: professional advisors who provide professional services to us, such as consultants and legal advisors.
    • Third-party service providers: We engage third party providers who may process your Personal Data on our behalf for the purposes mentioned above. These include the following:
      • Administrative services.
      • Advertising and communication services.
      • Corporate social responsibility services.
      • Maintenance services.
      • Physical security services.
      • Archiving, custody, storage and digitization services.
      • Document removal and destruction services.
      • Services of back office .
      • Computer services.

    7. International data transfers

    Users residing in the European Union should note that their Personal Data will be transferred to certain recipients (primarily our third party service providers) that are located outside the European Economic Area (" EEA "), in countries with laws and practices that do not provide equivalent data protection rights for your Personal Data (e.g. Thailand, Colombia…). Where such transfers occur, we ensure that appropriate safeguards are in place to ensure that: a) the transfers are not made without our prior written consent; and b) there is an appropriate transfer mechanism, such as module 2 of the standard contractual clauses (as approved by the European Commission) or an adequacy decision from the European Commission, in place to protect your Personal Data. If you would like to know more about any transfer that may affect your Personal Data, please contact us by email dpo@holafly.com .

    8. Your data protection rights

    Right Detailed information
    Right of access
    You have the right to request a copy of the Personal Data Holafly holds about you and to access the Personal Data we store about you.
    Right to object You have the right to object at any time to the processing of your Personal Data where Holafly processes it on the legal basis of pursuing its legitimate interests.
    Right of rectification You have the right to have any inaccurate Personal Data Holafly holds about you updated or corrected.
    Right to erasure In certain circumstances, you may even have your Personal Data deleted. For example, if you exercise your right to object and Holafly has no overriding reason to process your Personal Data or if it no longer requires your Personal Data for the purposes set out in this Notice.
    Right to restriction of processing You have the right to ask Holafly to restrict the processing of your Personal Data in certain cases, for example, if you believe that the Personal Data we hold about you is inaccurate or if the use of your Personal Data is unlawful.
    Right to data portability You may request that Holafly provide you with the Personal Data you have provided in a structured, commonly used and machine-readable format.
    Right to file a complaint You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work or where the alleged infringement occurred. The relevant supervisory authority in Ireland is the Data Protection Commission. For further information, please see www.dataprotection.ie .
    Right to object to automated decision-making, including profiling You have the right not to be subject to a decision based solely on automated processing of your data, including profiling, which produces legal effects concerning you or similarly significantly affects you. We may not be able to comply with this request where the processing is necessary for entering into or performing our contract with them or where the processing is authorised under a law to which we are subject.

    9. How long we retain your Personal Data

    Generally, we store your Personal Data in accordance with our obligations under applicable Irish and EU laws and/or for the duration of our relationship with you and for a reasonable period after that relationship ends. Your Personal Data will be stored for as long as necessary for the benefit of the purpose(s) for which it was collected. The criteria used to determine retention periods include:

    • the duration of the contractual relationship plus 7.5 years from the termination date;
    • whether retention is prudent in light of Holafly's legal position (such as with respect to statutes of limitations, litigation, or regulatory investigations);
    • if Holafly is subject to any legal obligation; and/or
    • 6 months for connection history and call recording.

    10. Personal data of minors

    Holafly understands the importance of safeguarding the Personal Data of minors, which we understand to be those individuals under the age of 18 in Ireland or the equivalent age specified by law in your jurisdiction.

    Minors under the age of 18 are prohibited from using Holafly's services. We do not knowingly collect (nor do we knowingly allow any third party to collect) Personal Data from individuals under the age of 18. If we become aware that Personal Data has been collected from an individual under the age of 18, we will delete that Personal Data and terminate that individual's account as soon as possible.

    11. Who should I contact to exercise my data protection rights or for any queries relating to my Personal Data?

    Holafly has a Data Protection Officer in accordance with applicable law. If you have any questions about the information detailed in this Notice or wish to exercise your data protection rights, please contact our Data Protection Officer via dpo@holafly.com or with our customer service team via help@holafly.com .

    12. Updates to this Notice and other information

    We will make every effort to keep this Notice up to date. This Notice will be reviewed on a regular basis and may be amended and updated from time to time as necessary. Any updates to this Notice will be posted on this section of the website.

    This Agreement is written in English. In the event of a conflict between this English version of the Notice and any translated copy of the Notice, the English version shall prevail.

    This Privacy Policy was revised and posted on January 1, 2024.

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