Privacy Policy

BRIGHTCORE ENTERTAINMENT LTD, company number 17357935, trading as Kirosim, is responsible as controller for the personal information it processes in operating kirosim.com, administering customer relationships and handling purchases and enquiries.

Our registered office is Dept 6957, 196 High Road, Wood Green, London, United Kingdom, N22 8HH. For privacy questions or requests, contact info@kirosim.com and indicate that your message concerns privacy.

Connectivity and payment organisations may also process information for their own legal and operational purposes. Their role depends on the activity: not every organisation involved acts solely on our instructions.

The information relevant to your interaction may include:

• Contact and account information: your email address, name and other details you provide, account identifiers, authentication records and preferences.
• Order and payment records: Plan and destination selected, order reference, amount, currency, transaction status, refunds and information needed for billing or transaction verification. Information available to us depends on the payment flow; it may include limited payment-method details and a transaction reference.
• eSIM and service records: profile identifiers, delivery and installation status, validity, remaining allowance, usage totals and technical status information made available to us for fulfilment and support.
• Website and device information: IP address, browser and operating-system information, access times, requested pages, errors and security logs generated when interacting with the website.
• Support information: messages, complaint details and relevant diagnostic information or screenshots you choose to provide.
• Preference and consent records: cookie choices, marketing choices and records of notices or consents associated with an order.

This description does not mean that Kirosim receives every category for every user. A network's ability to process connection or location information does not mean that we receive a complete record of your browsing, communications or precise movements.

Do not send full card numbers, card security codes, account passwords or unrelated sensitive information to our support email. If additional verification is necessary, we will explain what information is needed and how to provide it appropriately.

We receive information directly from you when you browse, register, purchase, subscribe to communications or contact us. Technical information may be generated by your interaction with the website. We also receive relevant payment-status and service-status information from organisations involved in processing the transaction or supplying connectivity, and information from a person you authorise to act for you.

We use third-party information only where there is a lawful basis and a relevant operational need. If a new activity requires additional notice, we will provide it when appropriate.

When relying on legitimate interests, we consider the impact on your rights and use information proportionately. We do not treat every business purpose as automatically overriding your privacy.

Information needed to take payment, fulfil an order or verify eligibility is necessary for the relevant transaction. If you do not provide it, we may be unable to complete the purchase or resolve the request. Optional marketing and optional tracking are not conditions of buying a Plan.

If you opt in to promotional emails, you can unsubscribe through the link in those messages or by emailing info@kirosim.com. Withdrawal of consent does not affect processing that was lawful before withdrawal.

Order confirmations, installation instructions, security notices and messages about an active complaint are service communications. Unsubscribing from marketing does not prevent necessary messages about your purchase.

We may retain a minimal suppression record to respect an unsubscribe request rather than inadvertently adding the address back to a mailing list.

We disclose relevant information only to the extent needed for the purpose concerned. Recipient categories include:

• payment-processing organisations, banks and card networks involved in payment, authentication, refunds and disputes;
• eSIM provisioning organisations and mobile connectivity networks involved in delivering and operating the purchased service;
• infrastructure, hosting, data-storage, security and technical support providers supporting the website and its operation;
• email-delivery and customer-support providers where used to send service messages or handle requests;
• analytics or marketing providers only where those optional functions are used with the required consent;
• professional advisers where necessary for accounting, legal advice or a dispute; and
• courts, regulators, law-enforcement bodies or other authorised recipients where disclosure is legally required or otherwise lawful and necessary.

If the business is reorganised or transferred, relevant information may be disclosed under appropriate confidentiality and data-protection arrangements. We will explain a material change in responsibility for your information where required.

Service providers acting on our behalf must process information under appropriate instructions and safeguards. Independent controllers remain responsible for their own processing. Contact us for further information about recipients relevant to your data.

Travel connectivity may involve processing in the country where a Plan is used, and supporting infrastructure may involve processing outside the United Kingdom or European Economic Area. The locations involved depend on the destination and service arrangements.

Where a transfer is subject to UK or EU transfer restrictions, we must have a lawful transfer basis. Depending on the destination and arrangement, this may be an applicable adequacy decision or approved contractual safeguards, together with any required assessment and supplementary measures. We do not treat the purchase of an international Plan as blanket consent to all overseas transfers.

You may contact info@kirosim.com for information about the locations and transfer safeguards relevant to your personal information, including a copy or description of applicable safeguards, subject to lawful redactions.

We retain identifiable information only for as long as needed for its purpose and applicable legal requirements. Retention is assessed by record type:

• account information is needed while the account is active and for a proportionate period to complete closure, address unresolved matters and prevent misuse;
• order, payment and refund records are retained for applicable accounting, tax, dispute and legal-claim requirements;
• service and diagnostic records are retained according to their necessity for Plan administration, fault investigation and related disputes;
• support correspondence is retained according to the issue, its resolution and any continuing legal need;
• consent and suppression records are retained as needed to evidence and respect your choices; and
• security logs are retained according to the incident-detection and investigation need, with longer preservation where a specific incident or legal obligation justifies it.

The relevant criteria include the length of the customer relationship, whether an issue remains open, applicable statutory periods and whether the purpose can be achieved with anonymised data. We do not keep all categories indefinitely simply because an account once existed. At the end of the applicable period, records should be deleted or irreversibly anonymised; backup copies are subject to controlled retention and restricted use.

We use measures appropriate to the nature of the information and the risks of processing. Access should be limited to people and organisations that need it for the relevant function. No online service can promise absolute security.

Protect your account credentials and eSIM installation details. If you suspect a data-security issue, contact info@kirosim.com promptly without including unnecessary sensitive information. Where a breach triggers a legal notification obligation, we will provide the required notification.

Depending on applicable law and the circumstances, you may request access to your personal information, correction of inaccuracies, erasure, restriction of processing or a portable copy of information you provided. You may withdraw consent at any time.

You have the right to object to processing based on legitimate interests on grounds relating to your situation. You also have the right to object to direct marketing at any time.

Contact info@kirosim.com to exercise a right. We may ask for proportionate information to verify identity and protect another person's information. Requests are normally handled without charge and within one calendar month where UK or EU GDPR applies. Any lawful extension, clarification requirement or permitted fee or refusal will be explained within the applicable timeframe.

Rights are not absolute. For example, a deletion request does not necessarily require deletion of records that must be kept by law or are needed for a legal claim. We will explain any relevant limitation.

You may complain to the UK Information Commissioner's Office or another competent data-protection authority, including an authority in your country of residence where applicable. You do not have to complain to us first.

Payment authentication, security screening and eligibility checks may involve automated tools. If an automated check prevents you from completing or accessing an order, you may contact us to explain your circumstances and request a review.

Where processing involves a solely automated decision with a legal or similarly significant effect, we will provide the information and safeguards required by applicable law, including applicable rights to challenge the decision and obtain human intervention. This clause is not consent to such decision-making.

Our service is intended for people aged 18 or over. If you believe a person under 18 has provided personal information to us in connection with an account or purchase, please contact us so that we can investigate and take appropriate action, including retaining only what is needed to resolve the matter or comply with law.

We may update this Policy to reflect changes in our activities or legal requirements. We will publish the revised version and provide additional notice where a material change requires it. A new policy does not retrospectively create consent for a new use of your information.