Privacy Policy

Who We Are

We are APPCODIX LTD (“HiLibre”, “we”, “us”, “our”), a travel eSIM provider.

1. PROCESSING OF PERSONAL DATA

HiLibre processes your personal data to a limited scope to provide Services, process payments, and enable the functioning of our Website. We may process the following categories of personal data:

Account and Sign-up Information

Name and email address. We collect your full name and email address during registration. This information is necessary for establishing an Account, retrieving a lost password, and using the Services.

Order data. When you order Services we process certain order information (e.g., the data plan chosen, term, currency, status, approximate location based on IP address, etc.).

Payment-Related Information

Payment data.Our payment processing partners process basic billing information for payment processing and refund requests (such as date of purchase, payer’s IP address, zip code, card owner’s full name, and credit card information).

Fraud prevention.To prevent fraudulent payments, your personal data (such as payer’s email address and device information) may be verified by our and/or our payment processing partner’s fraud management tools.

Communication Data

Email address. We use your email address to: (i) send important updates related to your use of Services; (ii) respond to your requests or inquiries; (iii) send offers, surveys, and other marketing content (you can opt-out at any time).

Customer support inquiries. We keep information you provided to our customer support team as necessary to resolve your query.

Information Collected on Our Website

Access logs. Like most websites, our Website collects access logs (such as IP address, browser type, operating system) to operate our services and ensure their secure, reliable performance.

Cookies. Cookies, pixels, and similar technologies are small text or image files placed on your device when you visit our Website. Some cookies are essential for the Website to operate; others are used to improve functionality, analyze usage statistics, and for advertising purposes. See our Cookie Policy for details.

Device Information

We may collect device information including model, operating system version, and similar non-identifying information to monitor, develop, and analyze our Services.

2. GROUNDS FOR PROCESSING

Your personal data is processed:

• Where necessary to fulfill the contract with you (providing Services, processing purchase transactions, ensuring secure performance);
• When we have a legal obligation to process certain personal data (e.g., tax and accounting records);
• Where you have provided consent (e.g., marketing communications);
• Under the legal basis of our or third parties’ legitimate interest (detecting fraud, improving Services, managing business communications).

3. SHARING PERSONAL DATA

We do not share your personal data with third parties except as described in this Privacy Policy.

Technology Partner

We act as an agent for our technology partner eSIM Go to deliver Services. eSIM Go is a limited liability company incorporated in England and Wales (company number 12465777), registered at 8 North Bar Street, Banbury, Oxfordshire, OX16 0TB, United Kingdom. More information on how eSIM Go processes personal data can be found in their Privacy Policy.

Service Providers

We use third-party service providers to help with various operations, including payment processing, email automation, analytics, and diagnostics. Key service providers include:

• Marketing and analytics: Google Analytics, Firebase Analytics (Google), Amplitude;
• Payment processing: Stripe Inc., Stripe Payments Europe Ltd.

Legal and Business Transfers

We may disclose personal data to establish or exercise our legal rights, to comply with legal obligations, or in connection with a corporate merger, acquisition, or similar event. HiLibre will continue to ensure the confidentiality of personal data in such cases.

Cross-Border Transfers

We may store, access, and transfer personal data from around the world. We assess all cross-border data transfers and have suitable safeguards in place, including standard contractual clauses approved by the European Commission where applicable.

4. YOUR DATA RIGHTS

Subject to applicable data protection laws, you may have the following rights:

• Delete: request us to erase your personal data;
• Access: know and access personal data HiLibre has collected about you;
• Rectify: correct, update, or complement inaccurate or incomplete personal data;
• Object: object to processing based on legitimate interests (e.g., for marketing);
• Portability: request a copy of your personal data in a machine-readable format;
• Restrict: restrict the processing of your personal data;
• Withdraw consent: where processing is based on consent;
• Lodge a complaint: lodge a complaint with a supervisory authority.

How to Exercise Your Rights

To update, access, or delete your data, or to unsubscribe from marketing communications, please contact us at support@hilibre.com.

5. DATA RETENTION AND DELETION

HiLibre will keep your personal data only as long as necessary to provide Services or as required by law. Specific retention periods:

• Personal data related to Services: 3 years from the last usage of the data plan;
• Personal data related to data usage: 30 days or as required by legislation;
• Customer billing information and payment details: 10 years from the last payment transaction;
• Customer support records: 3 years;
• Email for marketing: 1 year after the end of the user’s last data plan, or until opt-out, whichever comes first.

When we no longer have a legal ground to keep your personal data, it will be securely disposed of or anonymized.

6. COUNTRY-SPECIFIC PROVISIONS

For users in the European Economic Area (EEA)

If you are a resident of EEA countries, you can exercise your rights as provided in the EU General Data Protection Regulation (“GDPR”) by contacting us at support@hilibre.com.

For users in California

If you are a California resident, you can exercise your rights as provided in the California Consumer Privacy Act (“CCPA”) by contacting us at support@hilibre.com. HiLibre does not sell, share, lease, or rent your personal information.

7. CHILDREN’S DATA

HiLibre does not knowingly collect or solicit personal data from anyone under the age of 18. If we acknowledge that we have collected personal data from a child under 18, we will delete that data as quickly as possible.

8. UPDATES TO THIS POLICY

We may need to amend this Privacy Policy from time to time. If amendments materially affect the processing of your personal data, we will notify you in advance by reasonable means. Your continued use of the Services will be deemed acceptance of the updated Privacy Policy.