Oasis Smart-SIM Europe

PERSONAL DATA PROTECTION POLICY

Background

Oasis Smart SIM understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://www.oasis-smartsim.com/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the GDPR.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”

means Oasis Smart SIM, a limited company registered in France under siren number 522418516 whose registered address is 34 Rue de la Croix de Fer, 78100, Saint-Germain-en-Laye.
Information About Us
1. Our Site is operated by Oasis Smart SIM, a limited company registered in France under company number 522418516, whose registered address is 34 Rue de la Croix de Fer, 78100, Saint-Germain-en-Laye.
2. Our VAT number is GB 830849712.
3. Our Data Protection Officer is Alice Grand Chauvin and can be contacted by email at This email address is being protected from spambots. You need JavaScript enabled to view it. or by post at 34 Rue de la Croix de Fer, 78100, Saint-Germain-en-Laye.
What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
Your Rights
1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
  1. The right to be informed about Our collection and use of personal data;
  2. The right of access to the personal data We hold about you (see section 12);
  3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
  4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
  5. The right to restrict (i.e. prevent) the processing of your personal data;
  6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  7. The right to object to Us using your personal data for particular purposes; and
  8. Rights with respect to automated decision making and profiling.
2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):
1. name;
2. data of birth;
3. gender;
4. business/company name;
5. job title;
6. profession;
7. contact information such as email addresses and telephone numbers;
8. demographic information such as post code, preferences, and interests;
9. financial information such as credit / debit card numbers;
10. IP address;
11. web browser type and version;
12. operating system;
13. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How Do We Use Your Data?
1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
  1. Providing and managing your Account;
  2. Providing and managing your access to Our Site;
  3. Personalising and tailoring your experience on Our Site;
  4. Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
  5. Personalising and tailoring Our products and services for you;
  6. Replying to emails from you;
  7. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by:
    Our Opt-Out Policy. We may disclose your information to third parties for their direct marketing purposes. If you would like to opt out of such disclosures, please contact This email address is being protected from spambots. You need JavaScript enabled to view it.;
    
    Email marketing. To stop receiving newsletters or marketing communications from us or to opt out of having your email address shared with third parties, please use the “unsubscribe” mechanism provided in the communication (such as the “unsubscribe” link at the bottom of the marketing email) or send an e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. along with the information necessary for us to proceed your request.
  8. Service related announcements. We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. We do not offer an option to opt out of these emails, which are not promotional in nature.
  9. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
3. With your permission and/or where permitted by GDPR, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products & services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
4. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
5. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
  How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
  
  We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
  
  When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section "How to Access & Control Your Personal Data" below.
  
  If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How and Where Do We Store Your Data?
1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
2. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
3. Steps We take to secure and protect your data include:
  1. We store your person data on Hubspot. Their data Customer Data Protection include: Logical Tenant Separation, Encryption In-Transit (TLS 1.2, TLS 1.3), Encryption At-Rest (AES-256)
Do We Share Your Data?
1. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the GDPR.
2. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the GDPR.
3. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
4. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
What Happens If Our Business Changes Hands?
1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
How Can You Control Your Data?
1. When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
Your Right to Withhold Information
1. You may access Our Site without providing any data at all. However, to use certain features available on Our Site you may be required to submit or allow for the collection of certain data.
2. You may restrict Our use of Cookies. For more information, see section.
How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at This email address is being protected from spambots. You need JavaScript enabled to view it., or using the contact details below in section 14.

Our Use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products & services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for collecting analytics data, performing useful functions that help provide a good user experience, retargeting and ad-serving. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The following third-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
Hssc	This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. It expires in 30 minutes.	No
Hssrc	Determines if user has restarted their browser from Hubspot. Expiration period: session	No
Hstc	The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). Expiration period: session	No
Universal Analytics (Google) _ga _gat_UA-45691185-1 _gid	Cookie used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Expiration period: 1 day	No
Google Adsense _gcl_au	Cookie is placed by Google Adsense. The functionality is to store and track conversions. The purpose is Marketing/Tracking Expiration period: persistent	No
Hotjar _hjid	Cookie is placed by: Hotjar. The functionality is to store a unique user ID. The purpose is: Statistics Expiration period: 1 year	No
Hubspot	Hubspot’s tracking code collects information of how the user is interacting with the website and captures any information filled by the user via form fills.	No

Our Site uses analytics services provided by Hubspot and Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products & services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie	Purpose	Strictly Necessary
Hssc	This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. It expires in 30 minutes.	No
Hssrc	Determines if user has restarted their browser from Hubspot. Expiration period: session	No
Hstc	The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). Expiration period: session	No
Universal Analytics (Google) _ga _gat_UA-45691185-1 _gid	Cookie used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Expiration period: 1 day	No
Google Adsense _gcl_au	Cookie is placed by Google Adsense. The functionality is to store and track conversions. The purpose is Marketing/Tracking Expiration period: persistent	No
Hotjar _hjid	Cookie is placed by: Hotjar. The functionality is to store a unique user ID. The purpose is: Statistics Expiration period: 1 year	No
Hubspot	Hubspot’s tracking code collects information of how the user is interacting with the website and captures any information filled by the user via form fills.	No

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at This email address is being protected from spambots. You need JavaScript enabled to view it. or by post at 34 Rue de la Croix de Fer, 78100, Saint-Germain-en-Laye. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.