Privacy Policy
1. Controller
Bemi Prime Ltd ("Wayline") is the controller of personal data described in this policy. Contact our privacy team at info@waylinesim.com. [Insert Data Protection Officer or EU/UK representative details if required.]
2. Information we collect
- Account and order data: name, email address, billing country and postcode, order history, and billing address.
- Payment data: processed by our payment provider. We receive a payment reference, card brand, last four digits and expiry for saved cards; never the full card number or security code.
- eSIM data: ICCID, eSIM installation codes (encrypted at rest), activation status and, where Network Partners provide it, data usage.
- Support data: messages, attachments you choose to send, and ticket history.
- Technical data: IP address, device and browser information, and security logs (for fraud prevention and account security).
- Analytics (with consent): first-party usage events such as searches and checkout steps, linked to a random identifier.
3. Processing purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Selling and delivering Plans, processing payments, issuing eSIMs | Contract |
| Customer support and service messages | Contract; legitimate interests |
| Fraud prevention, security, rate limiting | Legitimate interests; legal obligation |
| Accounting, tax and invoicing | Legal obligation |
| Newsletter and marketing emails | Consent (withdraw any time) |
| Analytics to improve the site | Consent |
4. Payment providers
Payments are processed by [Stripe Payments Europe Ltd / Stripe, Inc.; confirm entity], which acts as an independent controller for payment and fraud-prevention purposes. See their privacy policy.
5. Telecom partners
To issue and operate your eSIM we share the minimum necessary data (such as order reference and, where a destination legally requires it, identity information) with our wholesale connectivity providers and the mobile networks they use. [List Network Partner categories and any countries requiring registration.]
6. Other processors
We use service providers for hosting, email delivery, error monitoring and customer support tooling, under contracts that restrict their use of your data. [List processors before launch.]
7. Data retention
- Order, invoice and payment records: [e.g. 7 years] for tax and accounting.
- Account data: while your account is open, then deleted or anonymized within 30 days of a deletion request, except records we must keep.
- Support tickets: [e.g. 3 years] after closure.
- Security logs: [e.g. 12 months].
- Analytics events: [e.g. 13 months].
8. Cookies
We use essential cookies for sign-in, cart and preferences, and first-party analytics only with your consent. See our Cookie Policy.
9. Analytics
Analytics are first-party, stored on our own systems, and not shared with advertising networks. You can change your choice at any time by clearing the consent cookie.
10. Your rights
Depending on where you live, you may have the right to access, correct, delete, restrict or object to processing of your data, to data portability, and to withdraw consent. Contact info@waylinesim.com. You can also complain to your data protection authority [insert lead authority].
11. International data transfers
Your data may be processed outside your country, including by Network Partners in your destination. Where required, we use appropriate safeguards such as Standard Contractual Clauses. [Confirm transfer mechanisms per processor.]
12. Account deletion
You can request deletion from Account → Security. We complete requests within 30 days. Active eSIMs continue to work until they expire. We retain records we are legally required to keep.
13. Security
We encrypt sensitive data (including eSIM activation codes) at rest, use HTTPS everywhere, support two-step verification, and restrict staff access by role with audit logging.
14. Privacy contact
info@waylinesim.com · Bemi Prime Ltd, 128 City Road, London, EC1V 2NX.