Politique de confidentialité

Draft — legal review pending

This privacy policy is an initial version. It is being reviewed by our legal adviser and may be updated as a result.

1. Who we are

This policy explains how Acorn Enterprises (“we”, “us”), trading as Odyssey Global SIM, collects and uses your personal data when you use www.odysseysim.com and our SIM and eSIM services.

Acorn Enterprises is a sole proprietorship based at 1 Bromley Lane, Chislehurst BR7 6LH, Kent, United Kingdom. We are the controller of your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For any question about your personal data, write to Support@odysseysim.com.

2. The data we collect

Depending on how you use our services, we collect:

• account data: your first name, last name, email address, telephone number, country, preferred language and password (stored only in encrypted form);
• order data: the plans you buy, their price, the date of purchase, the destination and the payment status;
• payment data: payments are processed by Stripe. Your card details are entered directly with Stripe and never reach our servers; we receive only the information needed to match the payment to your order (transaction reference, status, card type and last four digits);
• eSIM usage data: the identifier of your eSIM (ICCID), its activation status, the validity period of your plan and the data volume used or remaining, as reported by our network partners;
• support data: the content of your messages to our support team and our replies;
• technical data: your IP address, browser and device type, and the date and time of your visits, recorded in our server logs.

We do not collect the content of your communications: Odyssey is a data-only service, and your calls and messages go through the apps you choose.

3. Why we use your data, and on what legal basis

• to create and manage your account, process your orders, deliver and activate your SIM or eSIM, and provide support — because this is necessary to perform our contract with you;
• to take payments and keep accounting records — because the law requires it;
• to keep our services secure and prevent fraud and misuse — on the basis of our legitimate interests;
• to improve our website and services — on the basis of our legitimate interests;
• to send you marketing messages — only with your consent, which you can withdraw at any time.

4. Who we share your data with

We never sell your personal data. We share it only with the service providers we need to run our services, and only as far as necessary:

• Stripe, which processes your payments;
• the mobile network operators and connectivity partners that provide your SIM or eSIM;
• the technical providers that host and run our website and platform;
• public authorities, when the law requires it.

5. International transfers

Some of these providers are located outside the United Kingdom — our servers are hosted in Germany, and Stripe may process data in the United States. Where data leaves the United Kingdom, it is protected either by UK adequacy regulations or by appropriate safeguards such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

6. How long we keep your data

• account data: for as long as your account is open, then deleted or anonymised within 12 months of its closure;
• order, payment and accounting records: 6 years from the end of the financial year concerned, as required by UK tax law;
• support messages: 3 years after your last contact;
• server logs: 12 months.

7. Cookies

Our website uses only the cookies it needs to work: one remembers your language, another keeps you signed in. During payment, Stripe sets its own cookies to secure the transaction and prevent fraud. We use no advertising or tracking cookies.

8. Your rights

Under the UK GDPR, you have the right to:

• access your personal data and obtain a copy of it;
• have inaccurate data corrected;
• have your data erased;
• restrict or object to its processing;
• receive your data in a portable format;
• withdraw your consent at any time, where processing is based on consent.

To exercise these rights, write to Support@odysseysim.com. We reply within one month.

If you are not satisfied with our answer, you can complain to the Information Commissioner’s Office (ICO), the UK data protection authority: ico.org.uk, telephone 0303 123 1113.

9. Security

We protect your data with appropriate technical and organisational measures: encrypted connections (HTTPS), encrypted passwords, and access to personal data limited to the people who need it.

10. Children

Our services are intended for adults. We do not knowingly collect personal data from children under 13.

11. Changes to this policy

We may update this policy. The current version is always the one published on this page, with its date.

12. Contact

Acorn Enterprises — 1 Bromley Lane, Chislehurst BR7 6LH, Kent, United Kingdom. Email: Support@odysseysim.com.