Privacy Policy

1. Overview

This Policy explains how 2nd SIM Limited (“we” or “us”) collects, uses, shares and protects your personal data when you use the 2nd SIM app (“Service”). We comply with the UK GDPR, Data Protection Act 2018 and applicable privacy laws.

2. Data Controller

2nd SIM Limited (Company No. 15847259)
86–90 Paul Street, London EC2A 4NE

3. Data We Collect

• Account Data: Name, email address, phone number, password.
• Transaction Data: Transaction amount, purchase date, service details.
• Usage & Crash Reports: App crash logs, device type, operating system, IP address, usage statistics.
• Communication Metadata: Call/SMS timestamps, duration, phone numbers involved (content is not stored).
• Optional Contacts Access: If you permit, we’ll sync your address-book contacts to show which friends use 2nd SIM. You can revoke this at any time.

4. Legal Bases for Processing

• Contract performance: To provide the Service you request.
• Legitimate interests: To improve the app, prevent fraud, secure our systems.
• Consent: e.g. access to contacts, marketing emails. You can withdraw consent at any time.
• Legal compliance: To satisfy tax, accounting or regulatory requirements.

5. How We Use Your Data

• Service Delivery: Connect your calls/SMS, manage your virtual number subscriptions.
• Payments: Process transactions via Stripe (we do not store full card details).
• Support & Communication: Respond to inquiries, send service updates.
• Analytics & Improvement: Analyse crash reports and usage to fix bugs and enhance features.
• Legal & Fraud Prevention: Detect and prevent abuse, comply with lawful requests.

6. Sharing Your Data

• Service Providers: Stripe (payments), telecom carriers, SMS gateways, cloud hosts, analytics tools, support platforms. All third parties act under contract to protect your data.
• Legal Requests: If required by law, regulation or court order.
• Corporate Transactions: In the event of a merger, acquisition or sale, with appropriate safeguards.
• With Your Consent: e.g. porting your number to another provider.

7. International Transfers

Your data may be stored or processed outside the UK/EEA (e.g. U.S. servers). We use standard contractual clauses or ensure “adequacy decisions” are in place to safeguard your rights.

8. Data Retention

• Account & Profile: Retained while account is active; deleted/anonymised after you close your account.
• Transaction Records: Kept for at least 6 years for tax/compliance.
• Crash & Usage Logs: Retained to diagnose and fix issues; deleted when no longer needed.
• Support Correspondence: Kept for case-handling and quality improvements.

9. Security Measures

We implement industry-standard safeguards:

• Encryption (TLS) in transit and at rest where appropriate.
• Access controls, authenticated employee access only.
• Regular security updates and monitoring.

Despite this, no system is perfectly secure. You also have a role in protecting your data—keep your password secret and notify us of any suspected breach.

10. Your Privacy Rights

Under UK GDPR/EU GDPR you have the right to:

1. Access your personal data.
2. Rectify inaccuracies.
3. Erase data (“right to be forgotten”), subject to legal exceptions.
4. Restrict processing in certain cases.
5. Object to processing based on legitimate interests or for direct marketing.
6. Data portability for data you provided via automated processing.
7. Withdraw consent at any time (e.g. for marketing or contacts access).

To exercise these, contact us at [email protected]. We’ll respond within one month (and may extend by two months if needed).

11. Children’s Privacy

Users under 13 must not use the Service. If we learn we’ve collected data from a child under 13, we will delete it promptly.

12. Changes to this Policy

We will update this Policy as needed. Significant changes will be highlighted in-app or by email. Continued use after updates means you accept them.

13. Contact Information

Data Protection Officer
2nd SIM Limited
86–90 Paul Street, London EC2A 4NE
Email: [email protected]