1. Who We Are

This Privacy Policy explains how TM App Company LLC (“22SIM”, “we”, “us”) collects, uses, shares, and protects personal information when you use our mobile apps, websites, and related services (the “Service”).

2. Scope

• This Policy applies to information processed in connection with the Service, including eSIM, VoIP, and other digital goods (“e-Goods”).
• It does not cover third-party websites, mobile carriers, app stores, payment processors, or partner services that have their own privacy policies.
• If local laws require additional disclosures (e.g., GDPR/UK GDPR, certain US state laws), those rights may apply to you depending on your location.

3. Data We Collect

We collect information in the following categories (some are optional depending on your use):

3.1 Information you provide

• Contact details: name, email address, phone number (including WhatsApp) if you provide them.
• Support communications: messages, attachments, and details you share with support (in-app chat, email, WhatsApp).
• Order inputs: destination selections, plan choices, and any required customer details for delivery or compliance.

3.2 Transaction & delivery data

• Purchase records: products purchased, timestamps, amounts, currency, order IDs, and delivery status.
• Payment data: payment method type and transaction references. We do not store full card numbers; payments are handled by payment processors.
• Digital delivery artifacts: in-app delivery availability and, if used, delivery to email/WhatsApp.

3.3 eSIM & connectivity data (technical)

• Device & app data: device model, OS version, app version, language, time zone, and identifiers (e.g., advertising ID where available/allowed).
• eSIM-related identifiers: plan identifiers, activation status, and technical references needed to provision the eSIM (may include eSIM profile identifiers depending on provider flow).
• Usage diagnostics: error logs, installation/activation events, and connectivity troubleshooting signals.

3.4 VoIP & communications data (if you use VoIP)

• Call/message metadata: call time, duration, routing status, and technical quality metrics.
• Content: we generally do not need to access call content; if recording is required for compliance or quality, we will provide notice where legally required.

3.5 Analytics, cookies & similar technologies

• Website cookies: pages visited, clicks, referral URLs, and session information.
• App analytics: events (screens, taps, crashes, installs), performance metrics, attribution, and campaign measurement.

4. How We Use Data

• Provide and deliver e-Goods: fulfill purchases, deliver eSIM profiles/codes in-app (and optionally by email/WhatsApp), and provide order history.
• Customer support: respond to requests, troubleshoot installation/activation, and resolve disputes.
• Payments & accounting: process payments via providers, reconcile transactions, and maintain finance records.
• Fraud prevention & security: detect suspicious activity, protect accounts, reduce chargebacks, and secure systems.
• Service improvement: app stability, bug fixes, diagnostics, and performance monitoring.
• Marketing & measurement: measure ad performance and improve campaigns (subject to your preferences and local law).
• Legal compliance: comply with applicable laws, lawful requests, sanctions/export restrictions, and telecom requirements where relevant.

5. Legal Bases (Where Applicable)

Depending on your jurisdiction, we rely on one or more of the following:

• Contract necessity: to provide the Service and fulfill your purchase.
• Legitimate interests: security, fraud prevention, service analytics, and improvements (balanced with your rights).
• Consent: for certain cookies, pixels, marketing, or device-level permissions where required.
• Legal obligation: accounting, compliance, and lawful requests.

6. Sharing & Disclosures

We may share information with:

• Connectivity partners: mobile network operators and eSIM aggregators to provision and operate connectivity.
• Payment providers: to process transactions and prevent fraud.
• Analytics & attribution: tools used to measure performance and marketing effectiveness, such as (depending on your platform/consent):
  • Google / Google Analytics
  • Firebase (Analytics, Crash reporting)
  • AppsFlyer
  • Meta (Facebook)
  • TikTok
  • Snap (Snapchat)
• Cloud & infrastructure: hosting, storage, messaging, monitoring, and security vendors.
• VoIP service providers: to enable calling/messaging (if you use VoIP features).
• Legal and safety: regulators, law enforcement, courts, or other parties when required by law or to protect rights and safety.
• Corporate transactions: in a merger, acquisition, restructuring, or asset sale (with appropriate safeguards).

No sale of personal data: We do not sell personal information in the ordinary meaning of “sell”. Some jurisdictions define “sale/sharing” broadly for targeted advertising; you may opt out where applicable (see “Your Rights & Choices”).

7. Cookies, Pixels & SDKs

• Cookies (web): used for essential site functions, preferences, security, and analytics. You can manage cookies via browser settings and (where available) a cookie banner.
• Pixels/Tags (web): may be used to measure conversions and campaign performance.
• SDKs (app): analytics and attribution SDKs help us measure installs, crashes, and app usage.
• Device permissions: we request permissions only when needed (e.g., notifications). You can change permissions in your device settings.
• iOS/Android controls: you can limit ad tracking and reset advertising IDs from your OS settings; where required, we use consent prompts (e.g., iOS App Tracking Transparency).

8. International Transfers

Because we use global service providers and connectivity partners, your data may be transferred to and processed in countries other than where you live. Where required, we use appropriate safeguards (such as contractual protections) to protect your information.

9. Data Retention

• Orders & billing: retained as required for accounting, audits, and legal compliance.
• Support records: retained to resolve issues and improve support quality.
• Security logs: retained for fraud prevention, security investigations, and system integrity.
• Analytics: retained in aggregate or pseudonymized form where feasible; retention may vary by tool settings.

10. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information, including access controls, encryption in transit where supported, monitoring, and least-privilege practices. However, no system is 100% secure; you also play a role by protecting your device and access to email/WhatsApp used for delivery.

11. Your Rights & Choices

Depending on your location, you may have rights to:

• Access a copy of your personal information.
• Correct inaccurate information.
• Delete information (subject to legal retention requirements).
• Object/Restrict certain processing.
• Withdraw consent where processing is based on consent (without affecting prior processing).
• Data portability (where applicable).
• Opt out of targeted advertising where required by law (see “Marketing Preferences”).

We may need to verify your identity before fulfilling requests.

12. Marketing Preferences

• Email/WhatsApp marketing: if we send marketing messages, you can opt out using the unsubscribe link or by contacting us.
• In-app notifications: you can disable promotional notifications in device settings.
• Ads measurement: you can limit ad tracking via OS settings and cookie controls (web).

13. Children

The Service is not intended for children under 13, and purchases require adulthood (typically 18). If you believe a child has provided information, contact us to request deletion where applicable.

14. Third-Party Links

The Service may link to third-party sites or services (carriers, payment providers, app stores). Their privacy practices are governed by their own policies; we are not responsible for them.

15. Changes

We may update this Policy from time to time. The “Last Updated” date will change accordingly. If changes are material, we may provide additional notice within the app or website where appropriate.

16. Contact

For privacy questions or requests, contact us via in-app support or our official privacy channel.
[email protected]