1. Introduction

At YOZAX (“we”, “us”, “our”), we are committed to safeguarding the privacy of our users (“you”, “your”). This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use our services, specifically the free YOZAX eSIM. Our policy is designed to comply with international data protection laws, including but not limited to the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Privacy and Electronic Communications Regulations (PECR), and other applicable privacy laws across the countries where we operate.

As a free mobile network provider offering services to users around the world, we understand the importance of maintaining the highest standards of data protection and privacy. By using our services, you acknowledge and agree to the terms set forth in this policy and those in our primary Privacy Policy. For any conflict that may arise, these terms shall prevail.

2. Data Controller and Data Protection Officer

YOZAX is the Data Controller responsible for the processing of personal data in connection with the services we provide. To ensure compliance with data protection regulations and to address any data-related concerns, we have appointed a Data Protection Officer (DPO). If you have any questions about this policy or your personal data, you can contact our DPO via email at DPO@YOZAX.COM

3. Types of Data We Collect

To provide you with our services, we collect and process various types of personal data. This data is collected either directly from you, automatically through your use of our services, or through third-party sources. The categories of personal data we collect include:

  • Identity Data: Name, date of birth, age, gender.
  • Contact Data: Phone number, email address, postal address.
  • Location Data: Rough geographical location (e.g., city or region) based on your mobile network usage and account choices.
  • Demographic Data: Residential status (e.g., homeowner, tenant), employment status, marital status.
  • Interest Data: Information about your interests and preferences, which may be collected through your interactions with our services or our advertising partners.
  • Technical Data: Device identifiers, IP address, browser type, operating system, and other technical information.
  • Usage Data: Information on how you use our services, including data usage patterns, interactions with SMS notifications from our advertising partners, and network performance data.
  • Marketing and Communication Data: Your preferences regarding receiving marketing materials and your communication preferences.

4. Legal Basis for Processing Personal Data

We process personal data in accordance with various legal bases depending on the nature of the data and the context in which we collect it. These legal bases include:

  • Consent: We process personal data based on your explicit consent when you opt-in to receive SMS notifications from our advertising partners. You have the right to withdraw your consent at any time, but this may affect your ability to use certain features of our services.
  • Legitimate Interests: We process personal data where it is necessary for our legitimate business interests, such as providing a functional mobile network, enhancing our services, conducting research and analysis, ensuring security, and delivering relevant advertising. We conduct a legitimate interest assessment to ensure that our interests do not override your fundamental rights and freedoms.
  • Contractual Necessity: Processing personal data is necessary for the performance of the contract between you and YOZAX. For example, we require certain information to provide you with free data and network services.
  • Legal Compliance: We may process personal data to comply with legal obligations, such as retaining data for tax, regulatory, or law enforcement purposes.

5. How We Use Your Personal Data

We use your personal data for various purposes, ensuring that such use is aligned with the principles of data protection and privacy. The primary purposes for which we use your personal data include:

  • Service Provision: To provide and manage our free mobile network services, including delivering 1GB of free data per month and maintaining the eSIM, which remains the property of YOZAX.
  • Communication: To communicate with you regarding your account, services, updates, and any changes to our terms and policies.
  • Marketing and Advertising: To send you SMS notifications from our advertising partners and personalise advertising content based on your demographics, interests, and usage patterns. This includes analysing your data to deliver targeted offers and promotions that are relevant to you.
  • Service Improvement: To monitor and analyse usage and performance data to improve our services, develop new features, and enhance user experience.
  • Security and Fraud Prevention: To detect, prevent, and address security threats, fraud, and other illegal activities. This includes using data for network security and monitoring for unauthorised access or usage.
  • Compliance and Legal Obligations: To comply with applicable laws, regulations, and legal processes, including responding to requests from public and government authorities.

6. Data Sharing and Disclosure

To provide you with our services and operate our business effectively, we may share your personal data with the following parties:

  • Advertising Partners: We may share personal information, such as location, age, gender, and interest subjects, with our advertising partners to enable them to deliver relevant SMS notifications. We ensure that our partners are contractually obligated to process your data in compliance with applicable data protection laws.
  • Service Providers and Processors: We engage third-party service providers to perform functions on our behalf, such as data hosting, analytics, customer support, and marketing services. These service providers are bound by confidentiality agreements and are only permitted to use your data as necessary to provide services to us.
  • Legal and Regulatory Authorities: We may disclose personal data to law enforcement agencies, regulatory authorities, or other government bodies if required by law, regulation, or legal process, or if necessary to protect our rights or the rights of others.
  • Business Transfers: In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our business, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that your data remains protected.

7. International Data Transfers

As an international company, we may transfer your personal data to countries outside your country of residence, including countries that may not have the same level of data protection as your home country. When transferring data internationally, we ensure appropriate safeguards are in place to protect your data, including:

  • Standard Contractual Clauses (SCCs): We use SCCs approved by the European Commission and other relevant authorities to ensure that personal data transferred outside the European Economic Area (EEA) or other regions with adequate data protection laws is protected.
  • Adequacy Decisions: For transfers to countries deemed to provide an adequate level of data protection by relevant data protection authorities.
  • Binding Corporate Rules (BCRs): For intra-group transfers, we implement BCRs to ensure the consistent protection of personal data within our corporate group.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. The criteria used to determine our retention periods include:

  • The duration of your relationship with us and the provision of services to you.
  • Legal requirements, such as retention periods mandated by law, regulations, or court orders.
  • The necessity of retaining data for legitimate business purposes, such as fraud prevention, dispute resolution, or enforcing our agreements.

We conduct periodic reviews of our data retention practices to ensure compliance with applicable laws and regulations.

9. Your Rights and Choices

Depending on your location and the applicable data protection laws, you may have the following rights concerning your personal data:

  • Right to Access: You have the right to request access to the personal data we hold about you and to receive information about how we process it.
  • Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
  • Right to Erasure: You have the right to request the deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or when you withdraw your consent.
  • Right to Restrict Processing: You have the right to request the restriction of processing your personal data in certain situations, such as when you contest the accuracy of the data.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.
  • Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when the processing is based on our legitimate interests.
  • Right to Withdraw Consent: If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates applicable data protection laws.

To exercise any of these rights, please contact our Data Protection Officer at DPO@YOZAX.COM. We may require additional information to verify your identity before fulfilling your request.

10. Security of Your Data

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. Our security practices include:

  • Encryption: We use encryption to protect personal data both in transit and at rest.
  • Access Controls: We implement strict access controls to limit access to personal data to authorised personnel only.
  • Security Audits: We conduct regular security audits and assessments to identify and address potential vulnerabilities.
  • Incident Response: We have established an incident response plan to handle any data breaches or security incidents promptly and effectively.

Despite our efforts, no security measures can guarantee absolute protection. We encourage you to take steps to protect your personal data, such as using strong passwords and safeguarding your devices.

11. Use of Cookies, Tracking Technologies, and Location Data

To enhance your experience and provide tailored services, YOZAX employs a variety of tracking technologies, including cookies, GPS, cellular triangulation, and other mechanisms to collect information about your interactions with our services. This section outlines how we use these technologies, the types of data we collect, and how you can manage your preferences.

11.1 Cookies and Similar Technologies

Cookies are small text files that are placed on your device when you use our services. They enable us to recognise your device and store information about your preferences or past actions. We use cookies and similar technologies such as web beacons, pixels, and local storage to collect and process data about how you use our services. This helps us to:

  • Enhance User Experience: Remember your preferences and settings to provide a more personalised and convenient experience.
  • Analyse Usage: Monitor how you interact with our services to understand usage patterns, improve performance, and develop new features.
  • Marketing and Advertising: Deliver targeted advertising and promotions that are relevant to your interests. We may use data collected through cookies to build a profile of your interests and preferences.

We categorise the cookies we use as follows:

  • Essential Cookies: Necessary for the operation of our services. These cookies enable basic functions like network management, authentication, and accessibility. Without these, our services would not function correctly.
  • Performance and Analytics Cookies: Collect information about how you use our services, such as pages visited and links clicked. This helps us understand and improve the functionality of our services.
  • Marketing and Advertising Cookies: Track your online activities to deliver more relevant advertising. They help us measure the effectiveness of our advertising campaigns and tailor content to your interests.

Managing Cookies: You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete cookies, or be notified before a cookie is placed on your device. However, please note that disabling cookies may affect the functionality of our services and your overall experience.

11.2 Location Data Collection

As part of our commitment to providing a free mobile network service, we collect and use location data to enhance our services and deliver location-based advertising. We employ the following methods to collect location data:

  • GPS Tracking: If you opt-in to location services on your device, we use Global Positioning System (GPS) technology to collect precise location data. GPS provides accurate, real-time information about your device’s geographical location, allowing us to tailor services and advertising based on your current position.
  • Cellular Triangulation: When GPS is unavailable or turned off, we use cellular triangulation to determine your rough location. Cellular triangulation involves using the signal strength from multiple cell towers to estimate your device’s location. This method is less precise than GPS but still provides a general idea of your whereabouts.

We use location data for the following purposes:

  • Service Provision: To provide you with network services, we need to know your location to connect you to the nearest cell towers and optimise network performance.
  • Personalised Advertising: We use location data to deliver SMS notifications and advertisements from our partners that are relevant to your geographic area. For example, we may send you location-based offers or promotions based on your proximity to certain businesses.
  • Analytics and Improvement: To analyse how users move within our coverage areas, identify network issues, and make informed decisions to expand or enhance our services.
  • Safety and Security: To detect and prevent fraudulent or unauthorised use of our network, and to provide you with safety-related features, such as emergency services access.

Managing Location Data: You can manage your location preferences on your mobile device. Most devices allow you to control location services, including enabling or disabling GPS and deciding which apps can access your location. Disabling location services may limit the functionality of certain features, such as location-based advertising or network optimisation. Disabling your YOZAX eSIM will prevent any cellular connection or location tracking.

11.3 Browsing History Collection

In addition to location data, we may collect and analyse your browsing history to better understand your interests and preferences. This includes information about websites you visit, search queries, and interactions with online content while using our network. We collect browsing data through the following methods:

  • Network Analytics: As a mobile network provider, we have the ability to monitor and analyse network traffic. This includes collecting data about websites visited, apps used, and the duration of online activities while connected to our network. This data helps us understand usage patterns and identify trends.
  • Third-Party Services: We may partner with third-party analytics and advertising services that use tracking technologies to collect browsing data. These services help us aggregate and analyse data to build interest profiles and deliver targeted advertisements.

We use browsing history data for the following purposes:

  • Content Personalisation: To provide you with personalised content and advertising based on your browsing habits and interests. For example, if you frequently visit websites related to travel, you may receive SMS notifications about travel deals.
  • Marketing and Advertising: To develop targeted advertising campaigns and promotions from our partners. We aim to provide you with relevant and engaging offers based on your browsing behaviour.
  • Service Improvement: To analyse how our network is used, identify trends in browsing behaviour, and make improvements to our services to enhance your overall experience.

Managing Browsing Data: You cannot manage what browsing data YOZAX collects or stores, but you can manage how your browsing data is collected and used by the services you visit through the privacy settings on your device and web browser. Many browsers offer features like “Do Not Track” and private browsing modes that limit the collection of browsing history. Additionally, you can opt out of personalised advertising by adjusting your advertising preferences on your device or by using opt-out mechanisms provided by third-party advertising services.

11.4 User Control and Consent

We value your privacy and strive to provide you with control over how your data is collected and used. When you first use our services, you will be prompted to provide consent for the use of GPS tracking, location data, and browsing history collection. You have the right to withdraw your consent at any time by simply disabling the eSIM.

11.5 Data Security and Anonymisation

We take the security of your location data and browsing history seriously. All data collected through GPS, cellular triangulation, and network analytics is protected using encryption and other security measures to prevent unauthorised access, alteration, or disclosure. Additionally, we apply data minimisation and anonymisation techniques where possible to reduce the risks associated with processing personal data.

11.6 Data Retention for Location and Browsing History

We retain location data and browsing history only for as long as necessary to fulfil the purposes outlined in this policy and to comply with legal obligations. We regularly review our data retention practices to ensure they align with our data protection obligations. After the retention period, data is either deleted or anonymised to ensure it can no longer be linked to an individual.

Summary

By using YOZAX’s services, you consent to the collection and use of your location data and browsing history as described in this section. We use these data points to provide a more personalised and efficient service, deliver relevant advertising, and improve network performance. We are committed to protecting your privacy and giving you control over how your data is used.

12. Changes to This Policy

We may update this Data Protection Policy from time to time to reflect changes in our practices, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by sending you an SMS or email notification. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

13. Contact Us

If you have any questions, concerns, or requests regarding this Data Protection Policy or your personal data, please contact our Data Protection Officer via email at DPO@YOZAX.COM

We are committed to addressing your concerns and ensuring that your privacy is protected in accordance with applicable laws.

14. Conclusion

By using YOZAX’s services, you acknowledge that you have read, understood, and agreed to this Data Protection Policy. We are dedicated to ensuring that your personal data is handled responsibly, securely, and in compliance with international data protection laws. Your privacy is of utmost importance to us, and we strive to maintain the highest standards of data protection.