Privacy Policy

1. Introduction

This Privacy Policy governs the manner in which Nomado, LLC ("Company," "we," "our," or "us") collects, uses, maintains, and discloses information collected from users (each, a "User," "you," or "your") of our website, mobile application, and related services (collectively, the "Services").

We are committed to protecting your privacy and ensuring transparency in our data practices. This policy complies with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant privacy regulations.

2. Information We Collect

We collect various types of information in connection with the Services, including:

2.1 Personal Information You Provide

• Account registration information (full name, email address, phone number)
• Authentication credentials (username, password, security questions)
• Payment information (credit card details, billing address)
• Communication data (customer support inquiries, feedback, correspondence)
• Profile information (preferences, settings, language selection)

2.2 Information Collected Automatically

• Device information (device model, operating system, unique device identifiers, IMEI)
• Usage data (pages viewed, features accessed, time spent, interaction patterns)
• Network information (IP address, carrier information, connection type)
• Location data (GPS coordinates, cell tower information, Wi-Fi access points)
• Cookies and tracking technologies (as detailed in our Cookie Policy)
• Log files (access times, browser type, referring URLs)

2.3 Information from Third Parties

• Payment processors and financial institutions
• Mobile network operators and telecommunications providers
• Analytics and marketing service providers
• Social media platforms (if you choose to connect your accounts)

3. How We Use Your Information

We process your personal information for the following lawful purposes:

3.1 Service Delivery and Performance

• Provision and activation of eSIM profiles and data services
• Processing transactions, payments, and billing operations
• Managing your account and authenticating your identity
• Maintaining, improving, and optimizing our Services
• Providing customer support and responding to inquiries

3.2 Communication and Marketing

• Sending transactional communications (confirmations, receipts, notifications)
• Delivering service updates, security alerts, and administrative messages
• Providing promotional materials and marketing communications (with your consent)
• Conducting surveys and collecting feedback to improve our Services

3.3 Security and Legal Compliance

• Detecting, preventing, and investigating fraud, security incidents, and abuse
• Enforcing our Terms and Conditions and other policies
• Complying with legal obligations, court orders, and regulatory requirements
• Protecting our rights, property, and safety, as well as that of our users

3.4 Analytics and Product Development

• Analyzing usage patterns and trends to enhance user experience
• Conducting research and development for new features and services
• Generating aggregated and anonymized statistical data
• Performing A/B testing and measuring service effectiveness

4. Data Sharing and Disclosure

We may disclose your personal information to third parties in the following circumstances:

4.1 Service Providers and Business Partners

• Payment processors and financial institutions for transaction processing
• Mobile network operators (MNOs) and telecommunications providers for eSIM service delivery
• Cloud hosting and infrastructure service providers
• Analytics, marketing, and advertising partners
• Customer support and communication platforms
• Security and fraud prevention services

These third parties are contractually obligated to process data solely for the specified purposes and in accordance with our instructions and applicable data protection laws.

4.2 Legal and Regulatory Compliance

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with legal processes, subpoenas, court orders, or governmental requests
• Enforce our Terms and Conditions and other agreements
• Protect against fraud, security threats, or illegal activities
• Safeguard the rights, property, or safety of our company, users, or the public

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of our assets, your personal information may be transferred as part of the transaction. We will notify you via email and/or prominent notice on our Services prior to such transfer and any consequent changes to this Privacy Policy.

4.4 Consent-Based Sharing

We may share your information with third parties when you have provided explicit consent or directed us to do so, such as when connecting social media accounts or authorizing integrations with third-party applications.

5. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Employee training on data protection and security best practices
• Incident response and breach notification procedures

While we employ commercially reasonable security measures, no system is completely secure. We cannot guarantee the absolute security of your information during transmission or storage. You are responsible for maintaining the confidentiality of your account credentials.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention criteria include:

• Duration of your account and active use of our Services
• Legal, regulatory, tax, and accounting requirements
• Resolution of disputes and enforcement of agreements
• Legitimate business interests and legal rights

When we no longer require your personal information, we will securely delete or anonymize it in accordance with applicable data protection laws.

7. Your Privacy Rights

Subject to applicable law, you have the following rights regarding your personal information:

7.1 General Rights

• Right to Access: Request confirmation of whether we process your personal data and obtain a copy of such data
• Right to Rectification: Request correction of inaccurate or incomplete personal information
• Right to Erasure: Request deletion of your personal information under certain circumstances
• Right to Restriction: Request limitation on how we process your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw previously given consent at any time

7.2 GDPR Rights (European Economic Area)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including the right to lodge a complaint with your local data protection authority.

7.3 CCPA Rights (California Residents)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information held by businesses
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising your CCPA rights

To exercise any of these rights, please contact us using the information provided in the Contact section. We will respond to your request within the timeframe required by applicable law.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. We ensure appropriate safeguards are in place for such transfers, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by relevant data protection authorities
• Other legally approved transfer mechanisms

9. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities and preferences. These technologies serve various purposes:

• Essential Cookies: Necessary for the operation of our Services
• Functional Cookies: Enable enhanced functionality and personalization
• Analytics Cookies: Help us understand how visitors interact with our Services
• Advertising Cookies: Deliver relevant advertisements and track campaign effectiveness

You can control cookie preferences through your browser settings. Note that disabling certain cookies may limit your ability to use some features of our Services. For more information, please refer to our Cookie Policy.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will take steps to delete such information from our systems.

11. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to such third-party services. We are not responsible for the privacy practices of third parties and encourage you to review their privacy policies before providing any personal information.

12. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. When we make material changes, we will:

• Update the "Last updated" date at the top of this policy
• Notify you via email or through a prominent notice on our Services
• Obtain your consent where required by applicable law

Your continued use of our Services after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through the following channels: