Privacy Policy
This Private Policy (hereinafter - "Policy") are binding and governs the relationship between the Customer ("You" and/or "Customer") and Individual Entrepreneur Kovalchuk Nikita Yur’evich (hereinafter – “SimHub" or “We”) this Policy are as follows:
GENERAL TERMS
This Policy describes how Individual Entrepreneur Kovalchuk Nikita Yur’evich, collects, obtains (receives), stores, protects, uses, destroys (erase), retrieves and otherwise legally processes Your Personal Data,types and categories of such Personal Data, and purposes and legal grounds of the processing, and informs You about Your rights regarding the processing of Your Personal Data by SimHub.
SimHub collects and processes Your Personal Data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred to as GDPR). Other regulatory enactments, and only only.:
- A clear purpose: the controller must specifically inform the customer of the use he will make of his personal data by collecting them.
- Relevant data: the controller must only collect data that is strictly necessary for his treatment; this is the principle of minimizing collection.
- The retention period: the personal data must be kept enough time for the controller to achieve its purpose; beyond that time, the data must be deleted.
- The rights of individuals: individuals can exercise their rights over the personal data held by the controller: access your personal data,, , rectification, limitation of processing, object to the processing of personal data or deleting. As a data subject You have the right not to be subject to profiling which significantly affects your interests.
SPECIAL TERMS ON DATA PROCESSING WHILE USING SIMHUB SERVICES
By using SimHub, You confirm,acknowledge and understand that SimHub is only the distributor of the Wireless Communication Services. SimHub by itself Is not a telecommunication, including, but not limited to wireless communication service operator or provider within the meaning of law, and in this respect, by accepting this Policy and using. SimHub Services You acknowledge and agree that some of Your pseudonymized/anonymized Personal Data, for example: location data and traffic data, will be processed by the telecommunication or wireless communication service operator/provider, in order to and within the purposes of providing You data.
SimHub warrants, that SimHub cooperates only with telecommunication or wireless communication service operators/providers, who:
- are the certified, registered or public telecommunication or wireless communication service operators/providers;
- are providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that any Your Personal Data processing will meet the requirements of GDPR, and other related regulatory enactments and ensure the protection of the rights of the You as data subject.
WHAT INFORMATION DOES SIMHUB COLLECT
General information
When you sign up to use the Services, we may collect personal data such as your name, surname, user name, unique user ID, email address, password, and place of residence and location information including time zone and language.
If you willingly submit any other materials to us such as articles, images, feedback, etc., than you also provide us such allowence in the same way as other personal data.
Personal data we collect automatically
When you access or use the Services, we may automatically collect the following information:
Device information
Device model, information about the operating system and its version, unique device identifiers, enabled device accessibility features (e.g., display features, hearing features, and physical and motor features), mobile operator and network information, device storage information, or version of your device system.
Location information
IP address, time zone, or information about your mobile service provider;
Data about your use of the Services, including, among other;
Frequency of use; areas and features of the Services that you access, visit, or use or engagement with particular features.
Data from external sources
We may receive personal data about you from third parties. For example, we may obtain information from third parties to enhance or supplement your existing information, including to customize your experience and for statistical purposes and analytics.
Cookies and local storage
SimHub may collect information using cookies, which are small data files stored on the hard drive of your computer or mobile device by a website. SimHub may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.
SimHub use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Sensitive Personal Data
Subject to the following paragraph, we ask that you do not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit content to the services, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us. Please note that even if these information are provided, we will not store them anywhere on our side.
HOW WE USE YOUR PERSONAL DATA
Depending on which features of the Services you use, we will process your personal data based on one or more of the following legal bases (we have included some examples):
Your consent: On the registration screen, you can give us permission to process personal data to provide the Services.
To fulfill our contractual obligations to you in order to provide the Services to you: We may process your personal data to fulfill our contractual obligation to you such as account management and other administrative purposes.
Legitimate interest: We may process your personal data in relation to our interests in providing the Services to you, including our interest in protecting the security and integrity of the Services. If we rely on this basis, our interests will not come before your rights.
Legal obligation: We may be obligated to process some of your personal data to comply with applicable laws and regulations.
Below, we describe the purposes for which we process your personal data and our lawful bases for doing so, including some basic examples:
To respond to your comments, questions, and requests and to provide customer service
Legitimate interest
We may process your name and email to reply to your support request or to contact you about a specific query or question you have raised.
For the customization of product and service offerings and making our recommendations to you, including for third-party products and offerings
Consent
We may offer you a discount on the purchase of traffic packages.
To monitor and analyze trends, usage, and activities in connection with our App
Legitimate interest
We may analyze your browsing activity in the App to ensure the App functions as it should in response to your interactions, fix issues, and improve your future experience.
To process transactions and send you related information, including confirmations and reminders for account management and other administrative purposes.
Contract
Using your device data, we may send you a push notification if your traffic package expires.
We use third party payment processors to assist us in processing your payment information securely. Such third party processors' use of your Personal data is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies
We will not process personal data in a way that is incompatible with the purposes for which it has been collected or authorized by you or collect any personal data that is not needed for the mentioned purposes.
We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our services as described in this Privacy Policy.
We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). SimHub will provide you with information about SimHub’s data and how it will be used upon request. Should your data stored by SimHub be incorrect, SimHub will correct it. In this regard, you can write to SimHub. In addition, customers can view the data in their account that SimHub has stored about them and correct it if necessary.
You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Services may be ineffective upon opt-out. You may also:
- access the data we hold about you at any time via your account or by contacting us directly;
- update or correct any inaccuracies in your personal data by contacting us;
- in certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
You may contact us at hello@simhub.me anytime for any other questions you may have about your personally identifiable information and our use of it.
COOKIES SIMHUB USE TYPE OF COOKIES
The Services use the following types of cookies for the purposes set out below:
Strictly Necessary Cookies: These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the sites or applications and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow the Services to remember choices you make when you use a site or application, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of your account or preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.
Performance Cookies: These cookies are used to collect information about traffic to the services and how customers use the services.The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to the websites that referred them, the pages visited, what time of day they visited, whether they have visited before, and other similar information.We use this information to help operate the services more efficiently, to gather broad demographic information and to monitor the level of activity on our services.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html
You can prevent the use of Google Analytics relating to your use of the services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeting Cookies / Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
DISABLING COOKIES
Google AdWords Conversion Tool: Privacy information of the provider(https://goo.gl/CUUMgi), Link to Opt-Out (https://goo.gl/ghZWnt).
On www.youronlinechoices.com you can read more about cookies and the individual providers. There you can also opt out of usage-based online advertising through one or more tools. To go directly to the preference manager, please click here.
DISCLOSURE
As a general rule, SimHub will not disclose any of your personally identifiable information except under one of the following circumstances:
- we have your permission, including the permission granted by your acceptance of this Privacy Policy;
- we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena;
- it is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data;
- where we need to share your information to provide the product or service you have requested;when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by SimHub. SimHub may share the non-personally identifiable information that SimHub gathers, in aggregate form only, with advertisers and other partners.
CHILDREN’S POLICY
The Terms & Conditions clearly provide that Customers must be 18. SimHub does not knowingly collect personally identifiable information from customers under 18. You as the Customer are liable for the compliance to such terms. If the laws of the state of Your permanent residence provide for a different age of majority, then You, starting and continuing to use SimHub products, guarantee that You are of the age of majority according to the laws of Your state.
In the event that we learn that we have collected any personal information from a customer under the age of 18, we will attempt to identify and delete that information from our database.
If you are aware that a person under the age of 18Â is using SimHub Products or Services, please contact us at hello@simhub.me and we will take reasonable steps to delete such person's information and/or account.
INTERNATIONAL USAGE
The Service is owned by SimHub and may be accessed in Europe and abroad. For data protection purposes, SimHub is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction. You, starting and continuing to use SimHub products, guarantee that You has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for You due to the absence of an adequacy decision and appropriate safeguards.
HOW DOES A USER CHANGE OR UPDATE INFORMATION?
If you have any questions or concerns about this privacy policy or would like the personally identifiable information that you have provided to be removed from our files or to be changed, please contact SimHub via email at hello@simhub.me.
SECURITY AND ENCRYPTION
We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at hello@simhub.me.
CHANGES TO THIS POLICY
We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the last updated date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.
This privacy policy is an integral part of the Terms & Conditions agreement. If any points are not regulated in the privacy policy, they are governed by the provisions of the Terms & Conditions agreement.