This Privacy Policy explains how SAIMING INC. ("SAIMING", "we", "us") collects, uses, shares and protects personal data when you use the SAIMING mobile app and related services (the "Service"). We do not sell your personal data, we do not show ads or send marketing, and we do not track you across other companies' apps or websites.
1. Who we are
The controller of your personal data is SAIMING INC., a Wyoming corporation, 30 N Gould St Ste R, Sheridan, WY 82801, USA. Contact us about privacy at cs@saiming.com.
2. Data we collect
| Category | What it includes | Where it comes from |
|---|---|---|
| Account | Email address, display name (optional), preferred language, time zone | You; Apple or Google when you sign in with them |
| Sign-in | One-time codes we email you; the account identifier and sign-in tokens Apple or Google gives us when you sign in with them | You; Apple; Google |
| eSIM | ICCID, activation code, SM-DP+ address, eSIM status, installation status | Our eSIM network partner |
| Usage | Data used per session, date and time, the country and mobile network (MCC/MNC) where it was used, remaining data and balance | Our eSIM network partner's usage records |
| Network events | Our network partner's event notifications (for example when your eSIM connects in a new country, changes status or runs low on data) include your SIM's IMSI and network number (MSISDN), the country and network, and, for country changes, your device's IMEI. The MSISDN is a network identifier only; you cannot use it for calls or SMS | Our eSIM network partner |
| Purchases | Plans, top-ups, auto-renew and auto top-up settings, refunds, amounts and currency | You; Stripe |
| Payment | Card brand, last four digits and expiry, and a card fingerprint, as returned by Stripe. The fingerprint lets us recognise the same card used on different accounts, to prevent fraud and abuse of rewards. We never receive or store your full card number or security code. | Stripe; Apple Pay; Google Pay |
| Device and app | Device model, operating system and app version, push-notification token, IP address and user-agent | Your device |
| Diagnostics | Crash reports and error logs from the app and our servers (such as device model, operating system and app version), which can be linked to your account ID so we can investigate problems | Your device; our servers |
| Support | Emails you send to our support team, and the order you ask about | You |
Data that stays on your device. If you allow location access, the app reads your approximate location while it is open, and your phone's operating system checks it with Apple's or Google's location service to work out which country you are in, so the app can show local rates. The app does not send your device's location to SAIMING's servers; we do learn which country and mobile network your eSIM is used on from our network partner, as described above. The camera is used only if you choose to scan a payment card; the scan is processed on your device by Stripe's SDK. Saving a QR code to Photos only adds an image; the app cannot read your photo library.
Our network partner's usage records also contain technical identifiers, such as your SIM's IMSI, the IP address assigned on the mobile network and the cell used. We discard these identifiers when we process the records and keep only the date, time, data volume, country and network. We do not collect your physical address, precise GPS location, contacts, browsing history or advertising identifier.
3. How we use your data
| Purpose | Data used | Legal basis (EEA/UK) |
|---|---|---|
| Create and secure your account, sign you in | Account, sign-in, device | Contract |
| Issue your eSIM, apply plans and top-ups, show your usage and balance | eSIM, usage, network events, purchases | Contract |
| Take payments, run auto-renew and auto top-up, issue refunds | Purchases, payment | Contract |
| Send service messages: sign-in codes, eSIM installation, low-balance and data alerts, payment problems, and confirmations when you turn on auto-renew or auto top-up | Account, purchases, push token | Contract |
| Provide customer support | Support, account, purchases | Contract; legitimate interests (answering your questions) |
| Prevent fraud and abuse, enforce our Terms | Sign-in, device, purchases, payment | Legitimate interests (keeping the Service and our users safe) |
| Fix crashes and keep the Service reliable | Diagnostics, network events | Legitimate interests (a working Service) |
| Keep accounting, tax and dispute records | Purchases, usage | Legal obligation; legitimate interests (handling disputes and chargebacks) |
You need to give us an email address, directly or through Apple or Google, to create an account; without it we cannot provide the Service. Everything else is optional or collected automatically as described above. We do not use your data for advertising, profiling or direct marketing, and we do not make decisions with legal or similarly significant effects about you solely by automated means.
5. Payments
Payments are processed by Stripe, Inc. under Stripe's Privacy Policy. Your card details go directly from the app to Stripe. If you pay with Apple Pay or Google Pay, Apple's or Google's privacy terms also apply.
6. How long we keep data
| Data | Kept for |
|---|---|
| Account details | Until you delete your account, or we close it after 12 months without use (see section 7) |
| Sign-in, session and device records (including IP address, user-agent, one-time codes and push tokens) | Up to 180 days after the sign-in or the end of the session, and deleted when you delete your account |
| Technical records (network event notifications including IMEI, IMSI and MSISDN, payment notifications, service and email logs, crash reports) | Up to 180 days |
| Support emails | Up to 3 years after the conversation ends |
| eSIM details (ICCID, activation code, eSIM status) | As long as we keep the related order records |
| Orders, payments, refunds, usage records and account activity log | 7 years, to meet accounting and tax obligations and to handle disputes and chargebacks |
Deleted data can remain in our encrypted backups for up to about 30 days, until they are overwritten.
7. Deleting your account
You can delete your account in the app at any time, from your account settings. When you do, we delete or anonymise your account details, sign-in identities, sessions and device records, revoke your Sign in with Apple authorisation, and delete your Stripe customer record once any outstanding charges are settled. Your eSIM is deactivated. Order, payment and usage records are kept in pseudonymised form for the period in section 6. Deletion is permanent and the eSIM cannot be restored. If you have not used your account for 12 months and it has no balance and no active or unstarted plan, we may close it after emailing you at least 30 days in advance; the same deletion then applies.
You can also ask us to delete your account by emailing cs@saiming.com from the address on your account. We will email a confirmation code to that address; once you reply with the code, we complete the deletion within one month. If you signed in with Apple and chose Hide My Email, we cannot confirm by email that a request comes from you, so please delete your account in the app instead.
8. Your rights
Depending on where you live, you may have the right to access, correct, delete or export your personal data, to object to or restrict how we use it, and to withdraw consent. You can turn off location access or notifications at any time in your device settings. Residents of Hong Kong may request access to and correction of their data under the Personal Data (Privacy) Ordinance by writing to our Privacy Officer at cs@saiming.com or at the address in section 14. Residents of California and other US states may request to know, delete or correct their data; we do not sell or share personal data for cross-context behavioural advertising. To use any of these rights, email cs@saiming.com. We will respond within one month, or sooner if your local law requires, and will not discriminate against you for exercising them. You may also complain to your local data protection authority.
9. International transfers
We store your data on servers we operate in Hong Kong. Our service providers process data in the United States and other countries where they operate. Where the law requires safeguards for these transfers, we rely on the standard contractual clauses or equivalent safeguards in our providers' data processing terms.
10. Security
We use reasonable technical and organisational measures to protect your data, such as encryption in transit and of our backups, secure storage of sign-in tokens on your device, and limiting access to authorised staff. Anyone who has your eSIM's ICCID can check its remaining data without signing in, so keep your ICCID and QR code private. No system is perfectly secure; if a breach affects your data, we will notify you and regulators as the law requires.
11. Age
The Service is for people aged 18 or older, or the age of majority where they live. We do not knowingly collect data from anyone younger. If you believe a minor has given us data, contact us and we will delete it.
12. Tracking and analytics
The app does not use advertising identifiers, third-party analytics or advertising SDKs, and does not track you as defined by Apple's App Tracking Transparency framework.
13. Changes to this Policy
We will post changes here and update the effective date. If a change materially affects how we use your data, we will notify you in the app or by email before it takes effect.
14. Contact
SAIMING INC., 30 N Gould St Ste R, Sheridan, WY 82801, USA · cs@saiming.com