Simtex Privacy Policy

This privacy policy (“Privacy Policy”) governs the way RBCS ltd, a company incorporated under the laws of the State of Israel, P.C.N 515795821 (hereinafter, the “Company”, “we”, “our”) collects, uses, maintains and discloses the information of its users (hereinafter, “user”, “you”) via the Company’s Simtex application (which may be distributed via different platforms, such as Apple’s Appstore and Google’s Googleplay, Microsoft application store, etc.) (hereinafter, the “App”), when you use the App.

By using the APP, you accept this policy and terms of use which are an inseparable part hereof. If you do not agree to this policy, please do not use the APP.

The APP provides cellular roaming services for phone calls and internet bandwidth, while offering its users different roaming services options, via connecting to local and international roaming service providers, to enable its users to enjoy the best roaming plan (hereinafter, the “Services”).

What Type of Information is Collected by Us?

Please note that the scope of this Privacy Policy is limited only to information collected by Company through your use of its Services. Some information may be automatically collected, and some is collected when you interact with our App. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the App, the frequency and scope of your use of the Service and information about your mobile device and internet connection including the operating system you use and browser type.

Information from which you can be personally identified may also be collected, including but not limited to your name, email address, telephone number, and the location of the mobile device through which you used the Services(hereinafter: “PersonalInformation”). Personal Information shall be collected only if received voluntarily from you, including, without limitation, when you register to use the App and purchase any of the cellular plans available through the Services.

Technical Information Provided by Your Device

We always strive to optimize our App and Services, fix bugs and make our software better. Therefore, when you use your phone, tablet, computer or any other device on which you run the App or have App installed, we collect information from or about the device itself. We will combine the information about your account to give us a better understanding of your use of Services, so we can provide you with better and customized Services.

To make the Service tailored just for you, among other information, we collect the device’s geographic locations, and we retain all information which was sent to the App, including by Wifi, GPS or other means. Geographical information shall be collected by us also whether the App is turned off or logged out, and we monitor and record the location you visited and which is provided to us by your devices.

As part of our continuous optimization process, we collect the type and version of the device’s operating system, the App’s version being used by you and other device information such as hardware version, battery strength, device I.D and settings, internet service provider, languages set on the App, time zones, mobile operator, phone number and I.P address used to access the App. If you share your device’s address book, we will also collect this contact information.

Information about Payments

In order to improve your user experience in continuing to use the APP whenever you travel and wish to use our Services, and you make a payment for a roaming plan, we will collect information about your transaction. This includes all the payment information you submitted, such as the credit/debit card number which was used, or the account by which the payment has been made as well as your billing information.

Location Information

We may collect your location information to provide you with the Services. You are able to stop the collection of location information through your device settings; however, because such information is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of our Services.

Information We Collect from Other Sources

We may obtain information from other third-parties and combine it with information we collect through the App. For example, if you log into your account through a social media site, you will automatically grant us access to certain information on you which is stored on that site, such as your name, account information, friends list, etc.

How Do We Use Your Information?

We may obtain information from other third-parties and combine it with information we collect through the App. For example, if you log into your account through a social media site, you will automatically grant us access to certain information on you which is stored on that site, such as your name, account information, friends list, etc.

  1. Providing the Requested Services
    • We collect Personal Information to provide you with the Services you contracted to receive.
    • We collect and use the information you provide in any inquiry you make to respond to it and better understand the issue in question, your request or a remark you made.
    • We may send you confirmations, receipts, technical notices, updates, security alerts, support and administrative emails and/or messages as such collection of information will enable us to provide you with technical and professional assistance, with regard to the Services you use or intend to use.

    We process the Personal Information where it is necessary for the adequate performance of the contract regarding the requested Services.

  2. Improvement and Development of the Services
    • We collect Personal Information to improve and develop our Services and understand feedback on the Company’s Services and to help provide more information on the use of
      the Services. For example, we will present you with roaming offers, which are based on the information that we possess about your interests and your location. Such offers may
      also include third-party offers.
    • We collect Personal Information for ongoing review and improvement of the information provided on our App to ensure it is user friendly.
    • We collect Personal Information to improve the management and administration of our
      business and maintain compliancy with our internal policies and procedures.
    • We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.

    We process this information in light of our legitimate interest in improving the Services, to allow our users to have the best experience.

  3. Maintain a Safe and Secure Environment
    We may use your information to detect and prevent fraud, abuse and security incidents in the
    following ways;
    • Verify and authenticate your identity and prevent unauthorized or illegal activity;
    • Enhance the safety and security of our Services;
    • Conduct security investigations and risk assessments;
    • Prevent or take action against activities that are, or may be, in breach of our terms of Service or applicable law.

    We process this information in light of our legitimate interest in improving our Services and
    enabling our users to browse in a secure environment.

  4. Personalize Content, Advertising and Marketing
    • If you have used the Company’s Services in the past, we have a legitimate business interest for matching the data we collect with other data we had already
      collected.
    • This enables us to understand your needs and interests, optimize the content we send you
      and make it more suitable and relevant to your needs.
    • This also enables us to improve your experience on the App by providing you with personalized content, recommendations, and features.

    We process this information in light of our legitimate interest to personalize your experience and
    customize our content.

Disclosure of Information and Transfer of Data

Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Information, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.

In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Services or any portion thereof, such as marketing, data management or maintenance services. In particular we will share your Personal Information with local and international roaming service providers, to be able to provide you the Services according to the location where you will be situated (see more information below). Furthermore, when you are being directed to the App from third-parties, we receive information about you and your activities from such third-parties, to be able to provide you with the Services.

We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our App. This helps us compile aggregated statistics about the effectiveness of our App and Services.

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive. When such third party service providers process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements, and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the App or Services to perform an unlawful act or omission or take any act or omission that may damage the Company, its property and goodwill, or if there is an attempted breach of the security of the App or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

Transferring Information to Third-party Partners, Service Providers and Customers

We work with third party roaming services companies to provide and improve our Services to you. This cooperation allows the App to keep the Services free for you and continue to provide worldwide service and support.

We may transfer your Personal Information to third parties in order to provide us with technical services, or to analyze your use of the App, facilitate payments, measure the effectiveness of Services and more. Third-parties that receive such Personal Information are required to follow strict confidentiality obligations in a way that is consistent with this Privacy Policy.

Other Personal Information such as your phone number and different device or mobile subscription and identifying codes/numbers, will be transferred to the relevant third-party roaming service providers, subject to the conditions for such transfer under the applicable law.

We assure you that we will not send to advertising clients any Personal Information such as passport copies, names, I.D numbers, credit cards details, email address, or any other information that can be used for identity-theft and which can compromise your security and privacy in any way. Nevertheless, we will share anonymous demographic information of users, such as age, gender, location and interests

Your Rights

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at support@simtex.mobi.

In some jurisdictions, in particular those located within the European Union (the “EU”) or within the European Economic Area (the “EEA”), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Object to the processing of your Personal Information for direct marketing purposes.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. Object to an automated decision-making (including profiling) in certain circumstances.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our App, the Company is a “Data Controller”. Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request. If you wish to file a request regarding any of the above, you may contact us at: support@simtex.mobi.

How can I delete information collected about me?

If you wish to have your information and content deleted from the App’s database, you may submit a request by means of communications detailed provided in this Privacy Policy. We will need to ascertain your identity before we can proceed with the deletion process.

Access to information

Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact support@simtex.mobi.

Cookies

We may use “cookies” and/or other technologies or files (collectively, “cookies”) to identify how users make use of our App. This aggregated tracking information may be used to help us improve and enhance the App’s experience for all of our users. In addition, cookies are used for adjusting the App to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the App, the location from which you accessed the App and more. If you would prefer not to have cookies stored on your device, you may modify your browser settings to reject most cookies, or manually remove cookies that have been placed on your device. However, by rejecting the cookies, you may be unable to fully access the offerings on this App and our Services. To find out more about cookies, visit: www.allaboutcookies.org.

Opt In and Opt Out

You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to support@simtex.mobi. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

Links to Other Websites

This App may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by advertisers or other websites, companies or individuals, which are not owned or controlled by Company as well as other roaming service providers which provide you roaming services in the course of the Services. We suggest that when linking to another website or using a local roaming service via our Services, you always read that website’s or company’s privacy policy before volunteering any Personal Information.

How do We Protect Your Personal Information?

We take reasonable measures to implement security on the App and help protect your Personal Information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. Measures we take include encryption with SSL and periodic review of our collection of information, its storage and processing practices. We restrict access of your information only to those Company’s employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your information from unauthorized access.

Nevertheless, as the communications with the App is done by means of the internet, and as an online platform, we cannot guarantee that the use of the App or the interaction therewith will be 100% free viruses, worms, Trojans, and all other malware which are otherwise out of our reasonable control.

We train our personnel to their ability to recognize breaches of security of Personal Information, and their roles and responsibilities in our incident response plan. In case of a breach of security of Personal Information, the Company issues an immediate notification to the investigational, law enforcement, and other relevant authorities of the breach, and also notifies the data owner. Concurrently, we take measures to contain, control and correct any security incident that may involve Personal Information. We document all the steps to be taken following such breach. We
review the implementation of this plan annually, to ascertain there have been no material changes in the App by our personnel. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our site or to our partners, and transmission is at the users own risk.

Data Retention

Generally, the Company does not retain information longer than necessary to provide its Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your data, we will erase your Personal Information from our systems, unless the data is required for the Company to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.

Children's Privacy

The Service is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.

IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE SERVICE, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY

Questions Regarding Our Privacy Policy

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at support@simtex.mobi.
Alternatively, you may contact us here:
RBCS ltd.
Isserles st. 6,
Tel Aviv, Israel

Revisions and Modifications to our Privacy Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel, to the exclusion of any other jurisdiction.

This page was updated on 5th, August 2020

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