INTRODUCTION

eSim Travel Data Inc. (“ Solareo ”) recognizes the importance of your privacy and is committed to protecting your personal information. This Privacy Notice describes how Solareo collects, uses, shares, and protects your personal information when you use Solareo’s eSIM services, mobile application, website, and related services (collectively, the “ Services ”).

By using our Services, you agree to the collection and use of information in accordance with this Privacy Notice.

TABLE OF CONTENTS

1. Applicability of This Privacy Notice

2.Information We Collect

3. How We Use Your Information

4. How We Share Your Information

5. Data Retention

6. International Data Transfers

7. Your Privacy Rights

8. Cookies and Tracking Technologies

9. Security

10. Children's Privacy

11. Changes to This Privacy Notice

12. Contact Information

13. Additional Information for Specific Jurisdictions

1. APPLICABILITY OF THIS Privacy Notice

This Privacy Notice applies to all users of Solareo’s Services globally, including:

• Individual Users: People who use our Services for personal travel and connectivity needs.

• Business Users: Representatives and contacts of Solareo business customers, resellers, and partners.

• Website Visitors: Anyone who visits our website or interacts with our online content.

• Job Applicants: Individuals who apply for employment with Solareo.

2. INFORMATION WE COLLECT

Solareo collects information about you in various ways, depending on how you interact with our Services:

2.1 Information You Provide Directly

2.2 Information Collected Automatically

2.3 Information from Third Parties

• Payment processors and financial institutions

• Network operators and service providers

• Business partners and affiliates

• Social media platforms (when you connect accounts)

• Background check providers (for employment)

• Publicly available sources

2.4 Solareo as a data controller

Solareo assumes the role of data controller when it determines the purposes and means of processing personal data. As a data controller, Solareo is responsible for ensuring that personal data is processed in compliance with applicable data protection laws. Examples of Solareo’s responsibilities as a data controller include:

Direct Sign-Ups: Solareo is the data controller when users sign up directly with the service for Solareo’s consumer services.

Key activities:

• Service Delivery: Using data to provide Solareo's products and services.

• Fraud Prevention: Monitoring and detecting fraudulent transactions and activities.

• Legal Compliance: Adhering to applicable financial, legal, and regulatory obligations.

• Service Enhancement: Developing and improving products and services based on data analysis.

3. HOW WE USE YOUR INFORMATION

Solareo uses your personal information for the following purposes, which include but are not limited to:

3.1 Service Provision

• Creating and managing your account

• Processing orders and payments

• Delivering eSIM services and customer support

• Enabling eSIM activation and connectivity

• Monitoring service quality and network performance

• Processing refunds and returns

• Managing product exchanges and cancellations

• Backup and recovery of your account data

3.2 Communication

• Sending service-related notifications and updates

• Responding to your inquiries and support requests

• Providing marketing communications (with your consent)

• Sending important account and security alerts

• Sending transactional emails and receipts

• Providing technical support documentation

• Delivering service status and maintenance notifications

3.3 Business Operations

• Fraud prevention and security monitoring

• Legal compliance and regulatory reporting

• Internal analytics and business intelligence

• Service improvement and product development

• Risk assessment and management

• Website performance optimization and user experience enhancement

• Technical debugging and error identification/repair

• System maintenance and infrastructure management

• Internal administrative and relationship management activities

• Data quality assurance and validation

3.4 Legal Compliance

• Complying with applicable laws and regulations

• Responding to legal requests and court orders

• Protecting our rights and interests

• Enforcing our Terms of Service

3.5 Marketing

• Promotional Communications: Send marketing materials about our products, services, sales, and promotions

• Customer Communication: Respond to your requests, inquiries, and feedback

• Service Improvement: Analyze usage data to enhance our products and services

• Checkout Optimization: Streamline your purchasing experience

• Analytics: Conduct data analysis to understand customer preferences better

• Consent-Based Activities: Other marketing purposes you specifically consent to

You can opt out of marketing communications at any time through your account settings or by selecting “unsubscribe” on marketing materials.

3.6 Website and Technical Operations

• Identifying and authenticating users when visiting Solareo websites

• Streamlining checkout and purchase processes

• Optimizing website functionality and user interface

• Managing cookies and tracking technologies

• Ensuring website security and preventing unauthorized access

• Monitoring website performance and loading speeds

3.7 Data Management and Security

• Maintaining data integrity and accuracy

• Implementing security measures and access controls

• Conducting regular security audits and assessments

• Managing data retention and deletion schedules

• Ensuring business continuity and disaster recovery

3.8 Consent-Based Activities

• Processing data for purposes you specifically consent to

• Enabling optional features and enhanced services

• Facilitating third-party integrations you authorize

• Supporting promotional activities you choose to participate in

Although the sections above describe our primary purpose for collecting your information, in many situations, we have additional purposes. For example, if you complete an online purchase, Solareo may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete, so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

3.9 Sensitive Personal Data

Certain categories of information, such as biometric data, geolocation, or government issued identifiers, are considered “sensitive” under applicable law. Solareo will only collect and process such data where strictly necessary for Service provision (e.g., identify verification, fraud prevention), and only with your explicit consent where required under an applicable law (e.g., European Union (“ EU ”) General Data Protection Regulation (“ GDPR ”), UK Data Protection Act, California Privacy Rights Act). Sensitive data will never be used for marketing or profiling purposes without your consent.

4. HOW WE SHARE YOUR INFORMATION

Solareo may share your personal information with third parties in the following circumstances in order to deliver our Services, comply with the law, or support business operations. Sharing is always done in accordance with applicable privacy laws and, where required, with your consent.

4.1 Service Providers

Solareo shares information with third-party service providers who help us operate our business, including:

• Payment processors and financial institutions

• Network operators and connectivity providers

• Cloud hosting and data storage providers

• Customer support and communication platforms

• Analytics and marketing service providers

• Identity verification and fraud prevention vendors

4.2 Business and Integration Partners

Solareo may share data with select partners that help extend or enhance our Services:

• Network operators in destination countries

• Travel and booking platforms

• Technology partners and integrators

• Joint marketing partners (with your explicit consent)

4.3 Legal Obligation and Compliance

Solareo may disclose your information if required to do so by law or in response to valid legal requests, including:

• Government agencies and regulatory authorities

• Law enforcement agencies

• Courts, tribunals, and legal proceedings

• Subpoenas, warrants, or lawful orders

4.4 Corporate Transactions

In the event of a business transaction, Solareo may transfer your information as part of:

• Mergers, acquisitions, or divestitures

• Due diligence or negotiations

• Reorganizations or asset sales

4.5 Consent-Based Sharing

With your authorization, Solareo may share information with:

• The social media platforms you choose to connect with

• Third-party applications or services you authorize

• Marketing and promotional partners (with your consent)

4.6 Network and Connectivity Partners

To deliver roaming and mobile services, Solareo shares limited data with:

• Mobile Network operators and roaming partners

• Telecommunications infrastructure providers

• Global SIM provisioning platforms and signalling hubs

4.7 Platform and Technical Infrastructure Providers

Solareo partners with technology providers who help us maintain and enhance our Services:

• Cloud infrastructure and hosting services

• Customer support and communication platforms

• Analytics and performance monitoring tools

• Technology partners and integrators

• API, SDK and integration vendors

4.8 Distribution and Travel Ecosystem

Where relevant, Solareo may share data with:

• Online travel agencies and booking platforms

• Travel distribution channels and aggregators

• Hospitality and accommodation providers

• Platforms that resell or embed our Services

4.9 Connected Applications and Social Integrations

If you choose to connect third-party services:

• Solareo may share necessary account and usage data

• Information is shared only with your explicit permission

• You can disconnect integrations at any time via your account settings

4.10 Regulatory and Tax Disclosure

Where legally required, Solareo may share data with:

• Regulatory and supervisory authorities in relevant jurisdications

• Tax and customs authorities for compliance purposes

• Anti-money laundering or anti-fraud enforcement bodies

5. DATA RETENTION

Solareo retains your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Notice and to comply with legal obligations, including to satisfy any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law.

To determine the appropriate retention period for personal information, Solareo considers the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purpose for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

5.1 Retention Periods

Solareo stores data that identifies you for only as long as is necessary to provide our Services to you, or for the duration of our business relationship with you. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain purchase information for accounting, tax, security, and compliance purposes even after the immediate purpose of the data collection has been fulfilled or beyond the point at which our business relationship ceases. Retention timelines can be extended under legal holds or dispute situations.

6. INTERNATIONAL DATA TRANSFERS

Our Services operate globally, which means your information may be transferred to and processed in countries other than your country of residence, including countries that may not have the same data protection laws as your jurisdiction.

Nonetheless, where possible, we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.

By submitting your personal information to us, you agree to the transfer, storage, and processing of your information in a country other than your country of residence, including, but not necessarily limited to, the United States.

When Solareo transfers personal information outside of the European Economic Area, United Kingdom, or other jurisdictions with data export restrictions, we rely on legally recognized transfer mechanism, such as the European Commission’s Standard Contractual Clauses (“ SCCs ”) or the UK’s International Data Transfer Agreement (“ IDTA ”). We also implement supplementary technical and organization measures, including encryption and strict access controls, to ensure equivalent protection of your data.

Solareo strives to apply consistent privacy protections to your personal data across all jurisdictions where we operate. If you would like more information about how we apply the privacy principals of one jurisdiction to data that is transferred to another jurisdiction, please contact us using the details below.

7. YOUR PRIVACY RIGHTS

Depending on your location and applicable law, you may have the following rights regarding your personal information:

7.1 Access Rights

• Right to know what personal information we collect, use, and share

• Right to request a copy of your personal information

• Right to receive information about our data practices

7.2 Control Rights

• Right to correct inaccurate or incomplete information

• Right to delete your personal information

• Right to restrict or object to processing

• Right to data portability

• Right to withdraw consent

7.3 Communication Rights

• Right to opt out of marketing communications

• Right to manage cookie preferences

• Right to disable location tracking

7.4 Exercising Your Rights

To exercise your privacy rights:

• Log in to your account and update your preferences

• Contact us using the information in Section 12

• Use the unsubscribe links in our emails

• Adjust your device settings for location and cookies

Note: The validity of certain rights may be restricted by applicable law, legitimate business interests, or technical feasibility.

7.5 Verification of Requests

To protect your personal information, Solareo will verify your identity before responding to any rights request. Verification may include matching identifying information you provide with existing account data, or requesting additional information if needed. If you authorize our agent to make a request on your behalf, we may require written authorization and verification of your agent’s identity. Under GDPR, you also have the right not to be subject to automated decision-making, including profiling, which produces legal or similarly significant effects. We do not engage in such activities without your explicit consent.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance your experience and provide personalized services.

8.1 Types of Cookies

• Essential Cookies: Required for basic website functionality

• Analytics Cookies: Help us understand how you use our Services

• Marketing Cookies: Used for targeted advertising and personalization

• Preference Cookies: Remember your settings and choices

In the EU and UK, non-essential cookies will only be placed on your device with your prior consent. You may withdraw your consent at any time using our cookie management tool. Essential cookies required for basic site functionality do not require consent. For U.S. users, you may opt out of targeted advertising and tracking by using the opt out tools available in the cookie management tool.

8.2 Managing Cookies

You can control cookies through:

• Browser settings and preferences

• Our cookie management tool

• Third-party opt-out mechanisms

• Device settings for mobile advertising IDs

8.3 Third-Party Tracking

We may use third-party analytics and advertising services that collect information about your online activities over time and across different websites.

9. SECURITY

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security.

Solareo’s users remain responsible for keeping their passwords and credentials secure. If you have reasons to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at support@solareo.co .

10. CHILDREN'S PRIVACY

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 16 without parental consent. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.Children under the age of 13 should not provide their personal information to us.

Children under the age of 13 should not provide their personal information to us.

11. CHANGES TO THIS Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

11.1 Notice of Changes

• We will send email notifications for significant updates

• Continued use of our Services constitutes acceptance of changes

11.2 Effective Date

• Changes become effective immediately upon posting unless otherwise specified.

11.3 Review Encouragement

• We encourage you to review this policy whenever you visit our websites or applications

• Regular review helps you stay informed about how we protect your information

11.4 Date Definitions

• Effective Date: The date that the current version took effect

• Last Updated Date: The date that the current version was last substantively modified

• Both dates are clearly displayed at the top of this Privacy Notice

11.5 Notification Methods

• Email notifications will be sent to your registered email address

• We may use in-app notifications for mobile users

11.6 Reasons for Updates

• Changes in our business practices or service offerings

• Updates to technology and security measures

• New legal requirements or regulatory changes

• Industry best practices and compliance standards

• User feedback and operational improvements

11.7 Legal Framework

• We reserve the right to change these terms at any time

• Changes are made to ensure continued compliance and service quality

• Your rights and our obligations remain protected under applicable law

12. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Notice or our privacy practices, please contact us:

• Email: privacy@solareo.co

• Customer Support: Available through our mobile app

• For business inquires: bizdev@solareo.co

13. ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

13.1 European Union and United Kingdom

If you are located in the EU or UK, you have additional rights under the GDPR and UK data protection laws Each category of processing has a corresponding lawful basis under applicable law:

Legal Basis for Processing:

• Contract performance (providing our Services)

• Legitimate interests (improving Services, fraud prevention)

• Legal compliance (regulatory requirements)

• Consent (marketing, non-essential cookies)

Where we rely on a legitimate interest, Solareo carefully considers and balances our interests against your rights and freedoms, taking into account the nature of the data, your reasonable expectations, and the impact on your privacy.

Data Protection Authority: You have the right to lodge a complaint with your local supervisory authority if you believe we have not adequately addressed your concerns.

13.2 California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Notice.

California Shine the Light: If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the contact information provided.

Notice of Collection: The categories below describe the personal information we collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined by California law). Please note, in addition to the recipients identified below, we may disclose any categories of personal information with government entities as needed to comply with law or prevent illegal activity.

We collect the following categories of personal information:

• Identifiers (name, email, phone, IP address)

• Financial information (payment details)

• Commercial information (purchase history)

• Internet activity (browsing behavior, app usage)

• Geolocation data

• Biometric information (for identity verification)

Sales and Sharing Clarification: We do not "sell" your personal information for money. As discussed elsewhere in this Privacy Notice, we use cookies and similar tracking technologies for purposes of targeted advertising. For more information about tracking technologies, please see the Cookies and Other Technologies section of this Privacy Notice.

Your California Rights: If you are a California resident, you have specific rights under the California Consumer Privacy Act ( CCPA ) and California Privacy Rights Act(CPRA):

• Right to know about personal information collected, used, or shared

• Right to delete personal information

• Right to correct inaccurate personal information

• Right to opt-out of "sale" or "sharing" for targeted advertising

• Right to limit use of sensitive personal information

• Right to non-discrimination for exercising privacy rights

Business Purpose Disclosures: We may disclose personal information for business purposes to service providers, business partners, and other third parties as described in this Privacy Notice. All business purpose disclosures are governed by contractual restrictions on use and further disclosure.

Additional Information: For details regarding how we use personal information, please see the "Information We Collect" section of this Privacy Notice. Additional information can be found in other relevant sections of this Privacy Notice.

California Sensitive Information Disclosure: We collect the following categories of sensitive personal information (as defined under California law): biometric information, geolocation, social security number or other government issued ID information, account log-in, payment information. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.

Contact for California Requests: privacy@solareo.co

13.3 Other Jurisdictions

Solareo complies with applicable data protection laws in all jurisdictions where we operate. If you have specific questions about your rights under local laws, please contact us.

© 2025 Solareo. All rights reserved.

This Privacy Notice is designed to help you understand how we collect, use, and protect your personal information. We are committed to transparency and protecting your privacy.