Privacy Policy
Introduction
This privacy policy (“Policy“) is meant to inform you about how your Personal Data will be managed by Superhero Mobile Inc. (“Superhero Mobile,” “we,” “us,” or “our”) and outlines the information, including personal information detailed below relating to you or which you provide to us (“Personal Data“) that will be collected and processed by Superhero Mobile and/or on its behalf by its third-party service providers when you interact with us through our channels, such as our application, website, or once you have availed any of our services. We are committed to providing you with this information, including informing you about your data protection rights, in compliance with relevant data protection laws and regulations.
Superhero Mobile as Data Controller
For the purposes of this Policy, the controller of your Personal Data is Superhero Mobile Inc, located at Dublin, CA, US. Superhero Mobile is responsible for your Personal Data.
Superhero Mobile is committed to upholding your fundamental right to the protection of your personal data. This policy aims to inform you about how we process your personal data.
Types of Personal Data We Process about you
| Category of Personal Data | Details |
|---|---|
|
Website Usage and Device Data |
|
|
Customer Data |
|
Sources of your Personal Data
During the course of our contractual relationship with you or when you visit our website or application, we will collect Personal Data either: (1) directly from you, or (2) indirectly from third parties (for example, once you have contracted for our services, through our affiliates or travel agencies).
When you browse our website, various cookies and tracking devices may be installed on your device, as detailed in our Cookies Policy. For cookies that collect your personal data and are not essential for the website’s operation, we require your consent.
For what purpose and on what legal basis do we process personal data?
The table below outlines the key contexts (the “Legal Basis”) under which we process your personal data. It also details how (“Nature of Processing”) and why (“Purposes”) we collect and use your personal data.
| Legal Basis | Nature of Processing and Purposes | Categories of Personal Data |
|---|---|---|
|
Website Usage and
Device Data |
|
Customer Data Website Data |
|
Performance of a Contract |
|
Customer Data Website Data |
|
Legitimate Interest |
|
Customer Data Website Data |
With whom do we share Personal Data?
Depending on the Purpose for which we process your Personal Data, we may share such Personal Data with some or all of the following recipients to the extent necessary:
- Superhero Mobile internal/intra-group entities.
- Telecommunications service providers.
- Regulatory authorities and law enforcement agencies.
- Third-party advisors/professionals.
- Third-party service providers.
International Data Transfers
Users should note that your Personal Data may be transferred to certain recipients who are located outside the jurisdiction in which you reside, in countries with laws and practices that may not offer the same level of data protection as your home country. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your Personal Data.
Your data protection rights
Superhero Mobile respects your data protection rights, and you have certain rights regarding your Personal Data under applicable data protection laws. These rights include but are not limited to:
- Right of Access
- Right to Object
- Right to Rectification
- Right to Erasure
- Right to Restriction of Processing
- Right to Data Portability
- Right to lodge a complaint
- Right to Object to Automated Decision-Making, including Profiling
How long do we retain your Personal Data
We will store your Personal Data in accordance with our legal obligations and for as long as necessary for the purposes for which it was obtained.
Children’s Personal Data
Superhero Mobile understands the importance of safeguarding the Personal Data of children, and we do not knowingly collect Personal Data from persons under the age of 18. Children with the age of 18 or less are prohibited to use Supehero eSIM travel data services. We do not knowingly collect (or knowingly allow any third party to collect) Personal Data from persons under the age of 18. If we become aware that Personal Data has been collected from a person under the age of 18, we will delete this Personal Data and terminate that individual’s account as quickly as possible.
Who should you contact for exercising your data protection rights or for any questions relating to your Personal Data?
If you have any questions about this Policy or would like to exercise your data protection rights, please contact our Data Protection Officer at [email protected] or our customer service team at [email protected]
Updates to This Policy and Other Information
We will strive to keep this policy up to date. This policy will be regularly reviewed and may be amended and updated periodically.
Last updated on Wed 24 July, V 1.0
