Privacy Policy
Last updated: January 2024. This policy applies to holflysiminfo.site and is written in English.
1. Who We Are
HolFly Info operates the website holflysiminfo.site. We are a UK-based eSIM reseller. Our registered address is 15 Greenwich High Road, London SE10 8LH, London, England. You can contact us at [email protected].
2. What Data We Collect
We collect the following categories of personal data:
- Contact data: Name, email address, and any information you provide via our contact form.
- Transaction data: Order reference numbers and purchase records (processed by our payment provider).
- Usage data: Pages visited, time spent on site, browser type, and device type (collected via server logs).
- Cookie and localStorage data: We use localStorage to store your cookie consent preference (key:
cookieConsent_holflysiminfo.site).
3. How We Use Your Data
We use your personal data for the following purposes:
- To process your eSIM purchase and deliver your QR code.
- To respond to enquiries and support requests submitted via our contact form.
- To improve our website and services based on usage data.
- To comply with our legal obligations under UK law.
4. Legal Basis for Processing
We process your personal data on the following legal bases under UK GDPR: (a) performance of a contract — to fulfil your eSIM purchase; (b) legitimate interests — to improve our services and respond to enquiries; (c) legal obligation — to comply with applicable law; and (d) consent — for optional communications.
5. Cookies and localStorage
This website uses the following storage mechanisms:
- localStorage (cookieConsent_holflysiminfo.site): Stores your cookie consent preference. This is a functional necessity and does not track you.
- Server logs: Our web server automatically records standard access logs including IP addresses, pages visited, and browser information. These logs are retained for up to 30 days for security purposes.
We do not use third-party analytics, advertising cookies, or tracking pixels on this website.
6. Data Sharing
We do not sell your personal data to third parties. We may share your data with: (a) our eSIM network partners, to the extent necessary to provision your plan; (b) our payment processor, to process your transaction; and (c) law enforcement or regulatory authorities, if required by law.
7. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes described in this policy. Transaction records are retained for 7 years to comply with UK tax law. Contact form submissions are retained for up to 2 years. Server logs are retained for up to 30 days.
8. Your Rights
Under UK GDPR, you have the following rights:
- Right of access — to request a copy of your personal data.
- Right to rectification — to correct inaccurate data.
- Right to erasure — to request deletion of your data (subject to legal obligations).
- Right to restriction — to limit how we process your data.
- Right to portability — to receive your data in a structured format.
- Right to object — to object to processing based on legitimate interests.
To exercise any of these rights, email [email protected].
9. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction. Our website uses HTTPS encryption. We do not store payment card details.
10. Contact & Complaints
If you have questions about this Privacy Policy or wish to exercise your rights, contact us at [email protected]. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.