This Privacy Policy explains how Hala Media Marketing Services VSM, a company registered in Dubai, United Arab Emirates, trading as travaloSIM ("travaloSIM", "we", "us" or "our"), collects, uses, discloses, and protects personal data when you visit our website, use our app, or purchase and use our eSIM data plans (together, the "Services"). It should be read together with our Terms of Service.
We process personal data in line with the UAE's Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"). Because travaloSIM serves travelers connecting to networks around the world, we also describe below the additional rights available to residents of the European Union, the United Kingdom, and certain U.S. states.
1. Introduction
By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Services. Capitalized terms not defined here have the meaning given in our Terms of Service.
2. Information We Collect
| Category | Examples |
|---|---|
| Account & contact information | Name, email address, phone number, password (stored encrypted) |
| Billing information | Billing address and transaction details handled by our payment processors; we do not store full card numbers |
| Order & usage data | Plans purchased, eSIM identifiers (ICCID), Activation date, data consumption records, destination/country of use |
| Device & technical data | Device model and operating system, IP address, browser type, app version, approximate location derived from IP address |
| Communications | Messages you send to our support team, survey responses, and reviews you choose to share |
| Compliance information | Where a destination's local regulations require identity verification to activate mobile data (e.g. certain "know-your-customer" requirements), limited identity documents may be requested for that destination only |
| Cookies & similar technologies | Identifiers used to remember preferences and measure site performance, described further below |
We collect this information directly from you (for example, when you create an account or make a purchase), automatically through your use of the Services, and occasionally from trusted third parties such as our payment processors and Network Partners.
3. How We Use Your Information
- To create and manage your account and process your orders;
- To provision, activate, and provide the eSIM data Plans you purchase;
- To process payments and prevent fraud;
- To provide customer support and respond to your requests;
- To send transactional communications, such as order confirmations and low-data alerts;
- To send you marketing communications about products and promotions, where you have not opted out;
- To monitor, maintain, and improve the performance, security, and reliability of the Services;
- To comply with applicable legal, tax, and regulatory obligations, including UAE VAT and any destination-specific telecom regulations.
4. Legal Bases for Processing
Where applicable law requires a stated legal basis for processing (including for residents of the EU, EEA, and UK), we rely on one or more of the following: performance of our contract with you (providing the Services you purchase); our legitimate interests in operating and improving our business, provided these do not override your rights; compliance with a legal obligation; and your consent, such as for marketing communications, which you may withdraw at any time.
5. Cookies & Similar Technologies
We use cookies and similar technologies to keep you signed in, remember your preferences (such as currency and language), and understand how visitors use our website. You can control cookies through your browser settings; disabling certain cookies may affect the functionality of the Services. We do not currently respond to browser "do not track" signals.
6. How We Share Information
We do not sell your personal data. We share information only as follows:
- Service providers who help us operate the Services, including payment processors, cloud hosting providers, customer-support tools, and analytics providers, under contractual confidentiality and data-protection obligations;
- Network Partners to the extent necessary to provision and activate your eSIM and deliver connectivity in your destination, including any identity-verification data required by local telecom regulation;
- Legal and regulatory authorities, where required to comply with applicable law, respond to lawful requests, or protect our rights, property, or the safety of our users;
- Professional advisors, such as auditors, lawyers, and accountants, on a confidential basis;
- A successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy continuing to apply to your data; and
- With your consent, for any other purpose we disclose to you at the time of collection.
7. International Data Transfers
As a global Services provider, we and our service providers may store and process personal data outside the United Arab Emirates, including in the countries where our hosting and payment providers operate. Where we transfer personal data internationally, we use appropriate safeguards, such as contractual data-protection clauses, to ensure your data continues to receive an adequate level of protection consistent with the UAE PDPL and, where applicable, the EU/UK GDPR framework.
8. Data Retention
We retain personal data for as long as necessary to provide the Services, comply with our legal, tax, and accounting obligations (including UAE record-keeping requirements), resolve disputes, and enforce our agreements. When we no longer need your personal data, we securely delete or anonymize it.
9. Data Security
We use administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, or alteration, including encryption of stored passwords and use of PCI-compliant payment processors. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Your Rights
Subject to applicable law, you have the right to: request access to the personal data we hold about you; request correction of inaccurate or incomplete data; request deletion of your data; object to or request restriction of certain processing; request a portable copy of your data; and withdraw consent where processing is based on consent. To exercise any of these rights, contact us at support@travalosim.com. We may need to verify your identity before fulfilling a request. If you are not satisfied with our response, you may lodge a complaint with the UAE Data Office or, where applicable, your local data protection authority.
11. Regional Disclosures
European Union, EEA & United Kingdom
If you are located in the EU, EEA, or UK, the rights described above are provided in line with the EU/UK General Data Protection Regulation. You also have the right to lodge a complaint with your local supervisory authority. Where required, we will identify the specific legal basis relied on for a given processing activity on request.
California, USA
If you are a California resident, the California Consumer Privacy Act (as amended) gives you the right to know what personal information we have collected, used, or disclosed about you, to request deletion of your personal information, and to not be discriminated against for exercising these rights. We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under California law.
12. Children's Privacy
The Services are not directed to, and we do not knowingly collect personal data from, individuals under the age of 18. If you believe a minor has provided us with personal data, please contact us at support@travalosim.com so we can delete it.
13. Marketing Communications
You may opt out of marketing emails at any time by using the unsubscribe link included in those emails or by contacting us at support@travalosim.com. You will continue to receive transactional and service-related communications necessary to provide the Services, such as order confirmations and security notices.
14. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy on our website with a revised "Last updated" date, and where changes are material, we will provide additional notice, such as by email.
15. Contact Us
If you have questions about this Policy or how we handle your personal data, please contact us at:
Hala Media Marketing Services VSM (trading as travaloSIM)
Dubai, United Arab Emirates
Email: support@travalosim.com