Privacy Policy

1. Scope and Controller

This Privacy Policy explains how Comsand Inc., doing business as co:sim ("co:sim," "we," "us," or "our"), collects, uses, and discloses personal information when you use cosim.io, our applications, and our eSIM services. Comsand Inc. is a Delaware corporation with a registered office at 800 N King Street, Wilmington, DE 19801, United States.

Where data protection law uses the term "controller," Comsand Inc. is the controller unless this Policy says otherwise. Privacy rights vary by where you live and are described in Section 8.

2. Information We Collect

3. How and Why We Use Information

• Provide accounts, process orders, provision eSIMs, and deliver service communications
• Authenticate users, prevent fraud and abuse, secure our services, and enforce our terms
• Provide support, troubleshoot problems, and manage refunds
• Measure performance, understand product usage, and improve our services
• Attribute and measure advertising and show relevant marketing where permitted
• Comply with tax, accounting, regulatory, and other legal obligations

Where the GDPR, UK GDPR, or similar law applies, our legal bases depend on the activity and may include performing our contract with you, complying with law, our legitimate interests in operating and securing the service, and your consent. You may withdraw consent at any time, without affecting processing that occurred before withdrawal.

4. How We Disclose Information

We may disclose information to:

• eSIM suppliers and telecom partners to provision and operate your service
• Payment and fraud providers to process and protect transactions
• Hosting, security, email, analytics, advertising, error monitoring, and customer-support providers that process information for us or under their own notices
• Authorities and professional advisers when reasonably necessary to comply with law or protect rights, safety, and security
• Parties to a corporate transaction such as a merger, financing, acquisition, or sale of assets

We do not sell personal information for money. Some advertising disclosures may be considered a "sale," "sharing," or use for targeted advertising under certain U.S. state laws. Residents covered by those laws can opt out as described in Sections 7 and 8.

5. Data Retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy. Retention depends on the type of information, the duration of your account or service, legal and accounting requirements, fraud-prevention needs, and potential disputes. We then delete or de-identify information unless law permits or requires longer retention. Third-party providers apply their own documented retention periods.

6. Security

We use administrative, technical, and organizational safeguards designed to protect personal information, including encrypted transmission and access controls. No system or transmission is completely secure, so we cannot guarantee absolute security.

7. Tracking Technology Choices

Visitors in the European Economic Area, United Kingdom, and Switzerland are asked for consent before optional tracking technologies are enabled. Residents of U.S. states with applicable opt-out rights can use Cookie Settings in the site footer to opt out of relevant advertising technologies. We may make the same controls available in other locations as a convenience; doing so does not create rights that do not otherwise apply under local law.

Additional choices may be available through your device or browser, Global Privacy Control, or industry tools such as AdChoices. See our Cookie Policy for details.

8. Privacy Rights by Location

Depending on where you live and subject to legal exceptions, you may have rights to access, correct, delete, or obtain a portable copy of personal information; restrict or object to processing; withdraw consent; or complain to a regulator.

Residents of certain U.S. states may also have rights to confirm processing, opt out of sale, sharing, targeted advertising, or certain profiling, and appeal a denied request. We will not discriminate against you for exercising an applicable privacy right.

To submit a request, email privacy@cosim.io. We may need to verify your identity and authority. We will respond within the period required by applicable law. You may use an authorized agent where local law permits.

9. International Transfers

We operate internationally, so information may be processed in the United States and other countries where we or our providers operate. These countries may have different data protection laws. Where required, we use an approved transfer mechanism or other safeguards permitted by applicable law.

10. Children's Privacy

Our services are not directed to children under 18, and we do not knowingly collect their personal information. Contact us if you believe a child has provided personal information to us.

11. Changes to This Policy

We may update this Policy to reflect changes in our services, practices, or legal obligations. We will post the updated version and its effective date here and provide additional notice when required by law.

12. Contact Us

• Privacy requests and questions: privacy@cosim.io
• General support: support@cosim.io
• Customer support
• Comsand Inc.
  800 N King Street
  Wilmington, DE 19801
  United States