Privacy policy

Last updated - October 29th, 2025

195sim — Privacy Policy 

Effective Date: September 20, 2025
Company: 195sim LLC, a Wyoming limited liability company

Who We Are

We are 195sim LLC, a limited liability company organized under the laws of the State of Wyoming, United States of America, with its registered business address at 30 N Gould St, STE R, Sheridan, WY 82801, USA (“195sim”, “we”, “us”, “our”).

Under applicable privacy laws, we act as a data controller with respect to the personal data we collect and process in connection with the Services.

1. Introduction

195sim respects your privacy and is committed to protecting the personal data you provide while using our Services, including purchases, eSIM provisioning and customer support. This Privacy Policy explains what information we collect, why we collect it, how we use it, how we share it with Providers and other third parties, and how we protect it.

2. Data Controller

195sim LLC (the “Company”, “we”, “us”, “our”) is the data controller for personal information collected via the Services. Our primary contact for privacy questions is info@195sim.com. For the purposes of applicable privacy laws, 195sim determines the purposes and means of processing personal data in connection with the Services. 

3. Information We Collect

We collect information you provide directly and information collected automatically:

A. Information you provide:

• Account registration data: name, email, phone number, password (hashed).
  
  

• Order and payment information: billing address, payment token (we do not store full card numbers; processed via payment processors), purchase history, device model and IMEI/identifier where necessary for troubleshooting.
  
  

• Device and provisioning information: device model, OS version, eSIM identifiers, SM-DP+ and activation codes you provide during manual installation (limited storage), network/operator IDs relevant to provisioning.
  
  

• Support communications: messages, emails, chat logs where applicable.
  
  

B. Information collected automatically:

• Usage data: IP address, timestamps, app usage logs, plan usage (data volumes consumed per Plan), and aggregated telemetry for network/operational purposes.
  
  

• Diagnostic data: logs relating to provisioning, activation successes/failures, error codes to help debug installations.
  
  

4. How We Use Personal Data

We use personal data to:

• Provide and operate the Services, fulfill orders, provision eSIMs and activate Plans.
  
  

• Process payments, billing and refunds.
  
  

• Provide customer support and technical troubleshooting.
  
  

• Monitor service performance, detect fraud and abuse, and enforce Terms.
  
  

• Communicate important service notices and marketing communications (where you have opted in).
  
  

• Comply with legal obligations and respond to lawful requests.
  
  

5. Legal Bases for U.S. / EEA Users

• For U.S. users, we rely on contractual necessity (to perform the contract for the Service), consent (where required), legitimate interests (fraud prevention, network integrity, product improvement), and legal compliance obligations.
  
  

• For EEA users, where required by local law, we will rely on appropriate GDPR legal bases (contract performance, legal obligation, legitimate interests, consent for marketing).
  
  

6. Data Sharing and Third Parties

We share personal data with:

• Service Providers & Providers: third parties and underlying network operators and platform providers for provisioning and connectivity. Data sharing is strictly limited to what’s necessary to provision the eSIM, enable network attachment and process orders.
  
  

• Payment processors: Payment data is processed by third-party payment processors that we use to accept payments and detect/prevent fraud. We do not store full payment card numbers; tokens or limited billing info may be kept for refunds and accounting.
  
  

• Support and analytics vendors: We may share data with vendors who help us deliver customer support, debug provisioning issues, analyze service performance, and operate the app or website.
  
  

• Legal and regulatory: when required by law, legal process or to protect rights.
  
  

We require all vendors and Providers that process personal data on our behalf to implement appropriate security and confidentiality controls and to process data only in accordance with our instructions. Naming major processors improves transparency and aligns with best practice and typical privacy-policy structure. 

7. International Transfers

Because we and our Providers operate internationally, personal data may be transferred to and processed in countries other than your country of residence, including the United States. When transfers require safeguards under applicable law (for example GDPR), we put appropriate measures in place — for example, standard contractual clauses or other lawful transfer mechanisms — to ensure that your personal data receives an adequate level of protection. 

8. Data Retention

We retain personal data for as long as necessary to provide Services, fulfill business and legal obligations, resolve disputes, enforce agreements and for legitimate business purposes. Usage records and billing records are retained per accounting and legal requirements.

9. Security

We use administrative, technical, and physical security measures to protect personal data (for example: encryption in transit, access controls, network monitoring, vendor security reviews). While we use reasonable measures to protect data, no system is 100% secure. We will notify users and regulators as required by applicable law in the unlikely event of a data breach. This section follows Saily’s practical tone: transparent but not over-promising. 

10. Your Rights

Subject to applicable law, you may have rights to: access, correct, update, delete, restrict processing, receive a copy of your data, object to processing, and withdraw consent. To exercise rights contact info@195sim.com and we will respond as required by law.

11. Children

We do not knowingly collect personal data from children under 13. Minors (13–17) may use the Services only with parental consent. If we learn we have collected data from children under applicable thresholds we will take steps to delete it.

12. Cookies and Tracking

We and our service providers use cookies and similar technologies to provide the Services, measure performance and deliver ads. You can control cookie preferences via device or browser settings and in-app settings where available.

13. Marketing Communications

We may send promotional messages with your consent where required. You can opt out of marketing emails via the unsubscribe link in our emails or via account settings.

14. Changes to this Policy

We may update this Privacy Policy. Material changes will be posted with an updated Effective Date and, where required by law, we will notify you.

15. Contact & Complaints

For privacy inquiries or complaints contact: info@195sim.com.

16. Limitation of Liability

To protect your personal data, 195sim uses a range of technical, organizational, and security measures. However, it is your responsibility to exercise caution and good judgment when using our Services and Website.

You are personally responsible if your use of the Services violates any third-party rights, privacy laws, or other applicable laws.

To the maximum extent permitted by law, 195sim is not liable for the consequences of your unlawful, willful, or negligent activities, or for circumstances outside our reasonable control or foresight. Please also review our Terms of Service for additional limitations and disclaimers.