Privacy Policy for TravelSIM Compass

1. Data Controller

The Data Controller responsible for the processing of your personal data on the website airalos-online.click is TravelSIM Compass. Our commitment is to protect your privacy and handle your personal data with transparency and in compliance with applicable data protection laws.

You can reach us at:

• Company Name: TravelSIM Compass
• Address: 3-14-1 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan
• Email: [email protected]
• Phone: +81 3 6262 7841

As the Data Controller, we determine the purposes and means of processing personal data as outlined in this policy.

2. Data Collected

At TravelSIM Compass, we adhere to the principle of data minimization, collecting only the personal data that is necessary for the specific purposes outlined in this policy. We do not engage in extensive data collection practices or track user behavior across various platforms.

Information You Provide Voluntarily:

When you interact with our website, specifically through our contact form, we collect the following personal data:

• Name: To address you properly in our correspondence.
• Email Address: To respond to your inquiry and communicate with you regarding your message.
• Message Content: The text you submit in your inquiry, which may contain various pieces of information you choose to share with us.

This data is collected solely for the purpose of responding to your inquiries and providing assistance or information as requested by you. We do not use this data for marketing purposes unless explicitly consented to, which is not currently an option on airalos-online.click.

No Automated Data Collection for Tracking:

We explicitly state that TravelSIM Compass does not employ any third-party analytics tools, tracking pixels, or advertising technologies on airalos-online.click that collect personal data for behavioral tracking, profiling, or targeted advertising. Our website is designed to be free from such intrusive data collection methods. We do not gather IP addresses for tracking or location purposes beyond what is inherently part of standard web server logs (which are not used for individual user identification or tracking).

Any data collected is directly and intentionally provided by you for the specific purpose of communication with us.

3. Cookies and Local Storage

TravelSIM Compass utilizes cookies and local storage on airalos-online.click with a very specific and limited scope.

Purpose of Use:

The sole purpose for which cookies or local storage are employed on this website is to manage your consent regarding the use of cookies. When you interact with our cookie consent banner, a small piece of data is stored in your browser's local storage to remember your preference. This prevents the banner from reappearing on every subsequent visit, enhancing your browsing experience.

No Tracking or Analytics Cookies:

We categorically state that TravelSIM Compass does not use any tracking cookies, analytics cookies, or third-party cookies for monitoring user behavior, gathering statistical data, or for advertising purposes. Our website environment is designed to respect user privacy by avoiding such technologies.

Managing Your Preferences:

You typically have the option to manage cookie settings through your web browser. Most browsers allow you to refuse or accept cookies and to delete them. Please refer to your browser's help documentation for instructions on how to do this. However, please note that since our website only uses local storage for consent management, disabling all local storage might cause the cookie consent banner to reappear on each visit.

The data stored for cookie consent is non-identifiable and does not contain any personal information about you.

4. Legal Basis for Processing

The processing of personal data by TravelSIM Compass on airalos-online.click is carried out based on specific legal grounds as required by applicable data protection regulations. We ensure that every processing activity has a clear and legitimate basis.

Legitimate Interest:

The primary legal basis for processing the personal data you submit through our contact form (name, email, message content) is our legitimate interest. This legitimate interest lies in effectively responding to your inquiries, providing customer support, and addressing any questions or concerns you may have about our services or the information presented on TravelSIM Compass. We have assessed that our legitimate interests are not overridden by your interests or fundamental rights and freedoms, given the limited nature of data collected and its specific purpose.

Responding to user queries is an essential part of maintaining a functional and helpful website and ensuring a positive user experience. The data collected is directly relevant and necessary for this purpose.

Consent (for cookie preferences):

For the minimal use of local storage to remember your cookie consent preferences, the legal basis is your consent. When you interact with our cookie banner and make a choice, you are providing consent for us to store that preference locally in your browser. This consent can typically be withdrawn by clearing your browser's local storage or cookies.

We do not process any other categories of personal data, and therefore, no other legal bases are currently applicable for the operations of airalos-online.click.

5. Data Sharing and Disclosure

TravelSIM Compass places a high priority on the confidentiality of your personal data. We do not sell, rent, or trade your personal data to third parties for their marketing purposes or any other commercial use.

Internal Sharing:

Your data, primarily from contact form submissions, is accessed only by authorized personnel within TravelSIM Compass who require access to fulfill your request or provide support. This access is strictly on a "need-to-know" basis and is governed by internal policies and confidentiality agreements.

External Sharing (Limited Circumstances):

We may disclose your personal data in the following, very limited circumstances:

• Legal Requirements: If required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Protection of Rights: To protect the rights, property, or safety of TravelSIM Compass, our users, or the public, as required or permitted by law.

It is important to reiterate that TravelSIM Compass does not engage with third-party service providers for analytics, advertising, or extensive data processing that would involve sharing your personal data collected via the contact form. Our operational model on airalos-online.click minimizes the necessity for such external data sharing.

Any potential future engagement with service providers (e.g., email service providers if our communication methods expand) would be subject to strict data processing agreements ensuring the protection of your data in accordance with this policy and applicable laws.

6. Data Retention Period

TravelSIM Compass retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Contact Inquiries:

For personal data submitted through our contact form (name, email, message content), we retain this information for a period of up to 12 months from the date of the last communication. This retention period allows us to:

• Address follow-up questions or related inquiries efficiently.
• Maintain a record of correspondence for internal quality assurance and service improvement.
• Comply with any potential legal obligations related to business communications.

After this 12-month period, the data associated with your contact inquiry will be securely deleted or anonymized, provided there is no further legal or business necessity to retain it.

Cookie Consent Preferences:

The preference stored in your browser's local storage regarding cookie consent is typically retained until you clear your browser data or for a period defined by the browser's default settings (often several months to a year), after which the consent banner may reappear. This data is not stored on our servers.

In some cases, we may retain your data for a longer period if required by law or if necessary to resolve disputes, prevent fraud and abuse, or enforce our agreements.

7. Your Data Protection Rights

Under applicable data protection laws, particularly the General Data Protection Regulation (GDPR) for individuals in the EU/EEA, you have a number of important rights concerning your personal data. TravelSIM Compass is committed to upholding these rights.

• Right to Access (Article 15 GDPR): You have the right to request copies of your personal data that we hold.
• Right to Rectification (Article 16 GDPR): You have the right to request that TravelSIM Compass correct any information you believe is inaccurate or complete information you believe is incomplete.
• Right to Erasure (Article 17 GDPR): You have the right to request that we erase your personal data, under certain conditions.
• Right to Restrict Processing (Article 18 GDPR): You have the right to request that TravelSIM Compass restrict the processing of your personal data, under certain conditions.
• Right to Data Portability (Article 20 GDPR): You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Object to Processing (Article 21 GDPR): You have the right to object to TravelSIM Compass's processing of your personal data, under certain conditions, particularly when processing is based on legitimate interests.
• Right to Withdraw Consent (Article 7(3) GDPR): Where we rely on your consent for processing, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at [email protected] or via postal mail at the address provided in Section 1. We will respond to your request within one month, as required by law. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Please note that the applicability of these rights may vary depending on the specific circumstances and the legal basis for processing.

8. Right to Lodge a Complaint

While we encourage you to contact us directly to resolve any concerns you may have regarding our handling of your personal data, you also have the right to lodge a complaint with a supervisory authority.

If you are an individual within the European Union (EU) or European Economic Area (EEA), you have the right to complain to a data protection supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

For individuals in Japan, you have the right to lodge a complaint with the Personal Information Protection Commission (PPC) if you believe that your personal information is not handled appropriately by TravelSIM Compass.

We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance. You can reach us at [email protected].

9. Changes to This Privacy Policy

TravelSIM Compass reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or technological advancements. Any changes we make to our Privacy Policy will be posted on this page with an updated "Last Updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the personal data we collect. Significant changes will be communicated prominently on our website, or by other appropriate means, prior to the change becoming effective.

Your continued use of airalos-online.click after the effective date of the revised Privacy Policy constitutes your acceptance of the terms. If you do not agree with the changes, you should discontinue your use of the website.

10. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please do not hesitate to contact us. We are committed to addressing your inquiries promptly and transparently.

You can reach the Data Controller, TravelSIM Compass, through the following channels:

• Email: [email protected]
• Phone: +81 3 6262 7841
• Postal Address: 3-14-1 Hatchobori, Chuo-ku, Tokyo 104-0032, Japan

We will endeavor to respond to your communication as quickly as possible and, in any event, within the timeframes prescribed by applicable data protection laws.