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SIMZY Privacy Policy

Version 1.0.

Last updated: 07/01/2026.


1. INTRODUCTION

Simzy respects your privacy and is committed to protecting your personal data. This privacy policy aims to inform you about:

  • how we use your personal data you may provide us, while you enquire, purchase, or use any of our products or services including accessing contents of this website, signing up to our communications or taking part in our surveys or competitions.
  • the legal principles and lawful basis in which we process your data and
  • your rights regarding your personal data.

2. ABOUT US

We, Simzy, the trading name of Toggle Mobile B.V, provide electronic communication services including national and international data to customers. When we say, "we", "us" or "our" in this policy, we are referring to Simzy who is responsible for processing your data.


3. WHAT DATA DO WE COLLECT ABOUT YOU?

Personal Data is any information about you from which you can be identified. However, it does not include data where your identity has been removed (it’s called anonymised data).

We may collect, use, store and transfer different kinds of personal data which may be categorised as below:

  • Identity Data include your full name, date of birth, gender, language.
  • Contact Data include your correspondence address, email address, contact number.
  • Financial Data include your bank account and payment card details (which you provide to purchase products from us and make a payment directly to us, such as on our website).
  • Billing Data include your details about payments about the products and services you have purchased from us.
  • Technical Data include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform you use to access our website.
  • Profile Data include your username and password, purchases made by you, your interests, and preferences.
  • Usage Data include information about how you use our website, products and services, top up records, call data records which include traffic data and location data.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and other Simzy entities (as chosen and consented to) and your communication preferences.
  • Customer Care Data includes your feedback to us, survey responses and voice mail recordings when you contact us.

We process your personal data to derive information so that we can make personalised offers to our customers. Such information does not directly or indirectly reveal your identity. However, if we combine or connect the derived information with your personal data, it may directly or indirectly identify you. So, we also treat the derived information as personal data which will be used in accordance with this privacy policy. Where we need to collect personal data by law and you fail to provide that data when requested including updating data records or verifying the data, we may not be able to provide you with the products or services. We may also have to cancel a product or service you have with us but we will notify you if this is the case at the time.


4. HOW DO WE COLLECT YOUR PERSONAL DATA?

We obtain your personal data, directly and indirectly, when you:

  • Interact with our independent distributors, wholesalers, and retailers.
  • Interact with us when you provide your personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise.
  • Purchase and use our products or services or enquire about them.
  • Create an account on our website.
  • Subscribe to our services or communications.
  • Request marketing to be sent to you.
  • Enter a competition, promotion, or survey; or
  • Review our products and give feedback.
  • Download our app.
  • Access our website, using cookies. Please see our cookie policy for further details.

5. HOW DO WE USE YOUR PERSONAL DATA LAWFULLY?

We use your personal data complying to all data protection laws and regulations, most commonly, in circumstances where:

  • we need to perform services under the agreed terms and conditions with you.
  • it is necessary for our legitimate interests in course of our business.
  • we need to comply with a legal or regulatory obligation.

We have set out below, a description of all the ways and the lawful basis we use your personal data. In addition to your consent, legal, and regulatory purposes, we have also listed our legitimate interests including performance management, product offerings, market research where applicable, which may override your rights subject to the law.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.


PURPOSE

To register you as a new customer

  • Type of data (a) Identity (b) Contact
  • Lawful basis for processing including basis of legitimate interest

Performance of terms and conditions with you and where applicable, as required by law.


PURPOSE

To supply products and services to you including:

Managing payments

Collecting money owed to us

  • Type of data (a) Identity (b) Contact (c) Financial (d) Billing
  • Lawful basis for processing including basis of legitimate interest

(a) Performance of terms and conditions with you

(b) Necessary for our legitimate interests (to recover sums owed to us).


PURPOSE

To manage our relationship with you and administer your account which will include:

  • Notifying you about changes to our terms and conditions or privacy policy
  • Detecting and preventing crime and fraud • Asking you to leave a review or take a survey
  • Manage any concerns that you raise to our customer care department
  • Quality assurance and monitoring purposes
  • Type of data (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Customer Care (f) Usage
  • Lawful basis for processing including basis of legitimate interest (a) Performance of terms and conditions with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

PURPOSE

To enable you to participate in a competition

or complete a survey (non-promotional)

  • Type of data (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
  • Lawful basis for processing including basis of legitimate interest (a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

PURPOSE

To market products and services to you To complete a survey (promotional)

  • Type of data (a) Identity (b) Contact (c) Marketing and Communications (d) Profile
  • Lawful basis for processing including basis of legitimate interest (a) Legitimate interest to process marketing data (to grow our business) and consent for sending electronic marketing communications for new customers or reliance on existing customer relationship to send electronic marketing communications

PURPOSE

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • Type of data (a) Technical (b) Usage
  • Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

PURPOSE

To make suggestions and recommendations to you about goods or services that may be of interest to you

  • Type of data (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
  • Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to develop Simzy Mobile products/services and grow our business)

Marketing

You will receive marketing communications from us either if you have consented to receive them or purchased products or services from Simzy, and in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from other Simzy entities if you have consented to receive such communications on their Simzy products or services. Every communication either through email or text shall provide you with an option to opt-out/unsubscribe from such communications.


6. HOW CAN YOU MANAGE YOUR MARKETING PREFERENCES?

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting our Customer Services Department by sending an email to care@simzy.com


7. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

We may have to share your personal data with the parties set out below for the purposes set out:

  • Other Simzy group companies and associated enterprises who provide ancillary services such as IT Services, Customer Service support for the fulfilment of your orders and clarification of any of your queries.
  • Other Simzy Group companies where you have chosen to receive marketing communications from them on Simzy products and services other than Simzy.
  • External third parties who provide IT technical support services, data centre services and call centre support.
  • Regulators and judicial authorities who require reporting of processing activities in certain circumstances.

In case we choose to sell, transfer or merge parts of our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Where applicable, we require all external third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


8. WHERE IS YOUR DATA TRANSFERRED TO?

We transfer personal data to some of our related companies that provide services to us and to third party service providers. These parties may be based outside the European Economic Area (EEA). Specifically, Simzy uses related company service providers and third party service providers, including business support, customer service and technical services providers, based in India, Morocco and the Philippines and may use providers in other locations from time to time. Whether you are resident in the European Union, EEA or otherwise, you should note this transfer of personal data outside of the EEA and that this constitutes processing of your personal data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure that appropriate safeguards are in place, including requiring appropriate security measures from third parties to protect your personal data. We use specific clauses, prescribed by applicable Data Regulations including EU GDPR, in the contracts with our service providers.


9. HOW SECURE DO WE KEEP YOUR PERSONAL DATA?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a strict duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.


10. HOW LONG DO WE RETAIN YOUR PERSONAL DATA FOR?

We retain your personal data only for the period it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal and regulatory requirements.

Retention period for different category of your personal data varies and are subject to applicable laws and regulatory requirements, which are tabulated in our Data Retention Policy which you can request from us by Contacting our Customer Services Department.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.


11. WHAT ARE YOUR PRIVACY RIGHTS?

Subject to certain conditions under data protection laws where applicable, you have the following rights in relation to your personal data:

  • Right to obtain information about your processed data and right to have access to your personal data.
  • Right to correct your personal data – This enables you to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
  • Right to ask us to delete your personal data.
  • Right to object to the processing of your personal data.
  • Right to ask us to suspend the processing of your personal data.
  • Right to transfer your personal data -This enables you to ask us to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Note, however, that this right only applies to automated information for which you initially provided consent to be used to perform a contract with you.

  • Right to revoke your consent to the processing of your personal data.
  • Right to inform us of your wishes regarding the storage, deletion and communication of your personal data to a third party upon your death.

To exercise any of the rights set out above, please send your request to care@simzy.com and we shall respond, in accordance with the regulations, within the stipulated timeframe.


You may also reach out to our Data Protection Officer if you have any issues in enforcing your rights at DPO@simzy.com


Despite our best efforts, if any of your concerns remain unresolved, you may report them to the relevant Data Protection Supervisory Authority.


We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do contact us in the first instance.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information, if required, in relation to your request to expedite our response.


Time limit to respond

According to GDPR, all legitimate requests are required to be completed within one month, before which we shall complete the request. However, if your request is particularly complex or you have made several requests it may exceed the said period. In this case, we shall notify you and keep you updated.


12. CHILDREN'S PRIVACY:

Our website and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from any Child.


If you are under the age of 13, we request that you do not provide us with your information and do not use our website.


If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our website or otherwise provided their information to us without your consent.


We shall delete or otherwise cease processing your child’s personal information within a reasonable time to make sure that we do not contact you in the future.