eSIM Privacy Policy

Day Five Innovations Pty Ltd

We respect your privacy

Day Five Innovations Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. We adhere to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information in connection with our eSIM data plans and related mobile connectivity products (eSIM Services).

Personal information means information we hold which is identifiable as being about you.

eSIM Services

When you purchase, install, activate or use an eSIM Product through Tripply, you are using a telecommunications service that is delivered over mobile networks operated by third party carriers, their wholesalers and roaming partners (Carriers). Providing the eSIM Services necessarily involves the collection and processing of certain technical, network and account information so that an eSIM profile can be provisioned to your device and mobile service can be activated, operated, monitored and supported.

This section should be read together with the rest of this Privacy Policy. Where this section describes how we handle information specific to the eSIM Services, it adds to (and, to the extent of any inconsistency for the eSIM Services, prevails over) the more general descriptions below.

Collection of personal information

Day Five Innovations Pty Ltd will, from time to time, receive and store personal information you enter onto our software application Tripply, provide to us directly or give to us in other forms.

You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

Additionally, we may also collect any other information you provide while interacting with us.

eSIM and telecommunications information we collect

In order to provision, activate, operate and support the eSIM Services, we (and the Carriers and platform providers acting on our behalf) may collect, generate or process technical and network information associated with your device, your eSIM profile and your use of the eSIM Products, including:

• device identifiers, including the device EID, IMEI, mobile device type and model;
• the Integrated Circuit Card Identifier (ICCID) of your eSIM profile;
• the International Mobile Subscriber Identity (IMSI) and other eSIM profile identifiers associated with your eSIM profile;
• network provider identifiers and the mobile network or country in which your device is registered (country/network registration data);
• activation status of your eSIM Product, including whether a profile has been installed, activated, suspended or expired;
• data usage records, including data volume consumed, session times and the validity period remaining on a plan; and
• network and location-related information necessary to provide and support the service, as described under "Location information" below.

How we collect your personal information

Day Five Innovations Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our software application and when we provide our services to you. We may also receive personal information and telecommunications information from the Carriers, eSIM platform providers and other third parties involved in delivering the eSIM Services. If we do, we will protect it as set out in this Privacy Policy.

Use of your personal information

Day Five Innovations Pty Ltd may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

In connection with the eSIM Services, we may also use your personal information and telecommunications information to:

• provision eSIM profiles to your device and issue activation details such as QR codes and activation codes;
• activate, manage and operate your mobile service, including connecting you to the relevant Carrier networks;
• monitor and manage network usage and service quality, and enforce fair usage and acceptable use policies;
• troubleshoot connectivity, activation, compatibility and other service issues, and provide customer support;
• detect, investigate and prevent fraud, abuse, and unlawful or unauthorised use of the eSIM Services;
• bill for, and account for, the eSIM Products you purchase; and
• comply with our legal and regulatory obligations, including any applicable telecommunications laws.

The Application may make third party social media features available to its users. We cannot ensure the security of any information you choose to make public in a social media feature. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy.

Day Five Innovations Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.

Disclosure of your personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

Because the eSIM Services are telecommunications services, we will disclose certain personal information and telecommunications information (such as device identifiers, ICCID, IMSI, network registration data, activation status and usage records) to the participants in the telecommunications ecosystem that are necessary to provision and operate your service, including:

• eSIM platform and provisioning providers;
• telecommunications wholesalers and aggregators;
• mobile network operators (Carriers); and
• roaming partners and roaming hubs in the countries and regions where you use the eSIM Product.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Day Five Innovations Pty Ltd, its application, website and customers or third parties.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

By providing us with personal information, and by purchasing, activating or using the eSIM Services, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

Overseas disclosure and international transfers

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. These may include, but are not limited to, the United States, the European Union (including Spain) and other countries.

Because the eSIM Services are delivered over global mobile networks, your personal information and telecommunications information may also be stored in, processed in, or transferred through, the systems of the telecommunications ecosystem, including:

• Carrier and mobile network operator systems;
• roaming hubs and roaming partner systems;
• eSIM platform providers and telecom vendors; and
• cloud infrastructure providers,

which may be located in multiple jurisdictions, including the country or region in which you use the eSIM Product. Where you use an eSIM Product in a particular country, information necessary to provide the service in that location will be processed by the relevant Carrier and its partners in that country.

Where we transfer your personal information to countries outside Australia, we take reasonable steps to ensure such transfers are protected by appropriate safeguards, including, where applicable, Standard Contractual Clauses approved by the European Commission. You may request a copy of these safeguards by contacting our Privacy Officer.

Security of your personal information

Day Five Innovations Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Access to your personal information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 101 Moray St, South Melbourne, Victoria, 3205. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Opt out right

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at [email protected]. Please note that some information must be retained while you hold an active eSIM Product in order for us and the Carriers to provide and bill for the eSIM Services and to comply with our legal obligations, and that deleting an eSIM profile or uninstalling the Application will not necessarily terminate an active mobile service.

Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

Software Application

When you use our Application

When you come to our application we may collect certain information such as mobile unique device ID, the IP address of your mobile device, mobile operating system, the type of mobile internet browsers you use, and information about the way you use the Application. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

Cookies

We may from time to time use cookies on our software application. Cookies are very small files which a website uses to identify you when you come back to the application and to store details about your use of the application. Cookies are not malicious programs that access or damage your computer, tablet or smartphone. Most devices automatically accept cookies but you can choose to reject cookies by changing your devise settings. However, this may prevent you from taking full advantage of our application.

Automatic collection

The software Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, and the type of mobile Internet browsers you use, and information about the way you use the Application.

In connection with the eSIM Services, the Application and the eSIM platform may also automatically collect telecommunications information associated with your eSIM profile, including the device EID and IMEI, the ICCID, the IMSI and other eSIM profile identifiers, network provider identifiers, country and network registration data, activation status and data usage records, as described under "eSIM and telecommunications information we collect" above.

Third parties

Our software application may from time to time have links to other applications or websites not owned or controlled by us. These links are meant for your convenience only. Links to third party applications and websites do not constitute sponsorship or endorsement or approval of these third parties. Please be aware that Day Five Innovations Pty Ltd is not responsible for the privacy practises of other such applications or websites. We encourage our users to be aware, when they leave our application or website, to read the privacy statements of each and every application or website that collects personal identifiable information.

Location information

In connection with the eSIM Services, we and the Carriers may collect location-related network information, and, where you enable it, GPS or similar location information from your device. We may use this information to:

• determine coverage availability and the network on which your device is registered;
• activate and operate regional or country-specific data plans;
• monitor service quality and troubleshoot connectivity and activation issues;
• detect and prevent fraud and unauthorised use; and
• comply with applicable legal and regulatory obligations.

We will not share your precise location with other users. Network registration information (such as the country and network on which your device is operating) is inherent to providing a mobile telecommunications service and will be processed by the relevant Carriers and their partners as necessary to deliver the eSIM Services.