Politique de confidentialité
1. Introduction
Redeemso International B.V. (“Redeemso”, “we”, “us”, or “our”) operates an online platform (the “Platform”) that acts as an intermediary between Users and independent Vendors of Digital Content, including eSIM data plans and other digital products.
In connection with the operation of the Platform, Redeemso International B.V. processes personal data and acts as a data controller in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable data protection laws.
This Privacy Policy explains how personal data is collected, used, stored, and protected when you access or use the Platform, create an Account, complete transactions, or interact with our Services. The processing of personal data is limited to what is necessary to operate the Platform, comply with legal obligations, prevent fraud and abuse, and ensure the security and integrity of our Platform.
By accessing or using the Platform, you acknowledge that your personal data may be processed as described in this Privacy Policy.
2. Data We Collect
We collect various types of information to provide and improve our services:
2.1. Account and Contact Data
When you register or purchase as a guest, we collect identifiers such as your full name, email address, and optionally your phone number.
2.2. Transactional Data
We process details regarding your orders, including the products purchased, date and time of transaction, order value, and order history.
2.3. Identity Verification (KYC) Data
Important: To comply with legal obligations regarding anti-fraud, Anti-Money Laundering (AML), and Know Your Customer (KYC) regulations, we may request and collect copies of government-issued identification documents (e.g., passport, driver's license, ID card), proof of address, or selfies for liveliness checks. These documents are stored securely with restricted access and are retained only for the mandatory statutory retention periods required by law.
2.4. Technical and Device Data
We automatically collect technical data including your IP address, browser type and version, time zone setting, operating system, and platform to ensure security and proper rendering of the website.
2.5. Payment Data
We do not store complete credit card numbers. Payment transactions are processed by secure third-party payment service providers (PSPs). We receive only limited confirmation data (e.g., partial card number, transaction status) to verify payment completion.
3. Legal Bases for Processing
Redeemso International B.V. processes personal data only where a valid legal basis exists under Article 6 of the General Data Protection Regulation (GDPR). Depending on the circumstances, processing may be based on one or more of the following legal grounds:
3.1 Performance of a Contract
We process personal data where necessary to provide access to the Platform, facilitate transactions between Users and Vendors, deliver Digital Content, manage Accounts, and provide customer support services.
3.2 Legal Obligations
Certain processing activities are required to comply with applicable laws and regulatory requirements, including accounting obligations, fraud prevention measures, sanctions screening, and requests from competent authorities.
3.3 Legitimate Interests
Redeemso International B.V. may process personal data where necessary for legitimate business interests, provided that such interests do not override the fundamental rights and freedoms of Users. These interests include:
- • maintaining platform security and integrity;
- • detecting fraud, abuse, or suspicious activity;
- • improving Platform functionality and user experience;
- • enforcing geographic or regulatory restrictions.
3.4 Consent
Where required by law, we rely on your consent for specific processing activities, such as optional communications, certain analytics tools, or non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
4. How We Protect Your Data
Redeemso International B.V. implements appropriate technical and organisational measures designed to safeguard personal data against unauthorized access, loss, alteration, or disclosure. These measures include, where appropriate, encryption of data in transit (TLS/SSL), secure storage practices, access controls, monitoring mechanisms, and periodic security assessments.
In order to operate the Platform, certain personal data may be processed by carefully selected third-party service providers acting on behalf of Redeemso International B.V., including cloud hosting providers, payment service providers, fraud prevention systems, analytics tools, and technical partners involved in the delivery or provisioning of Digital Content and connectivity-related services. Such providers process data solely under contractual safeguards and in accordance with applicable data protection laws.
While we take reasonable steps to protect personal data, no system can be guaranteed to be completely secure, and Users should take appropriate measures to protect their own account credentials and devices.
5. Data Retention
Redeemso International B.V. retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including the operation of the Platform, compliance with legal obligations, fraud prevention, dispute resolution, and the protection of legitimate business interests.
Retention periods may vary depending on the type of data and applicable regulatory requirements:
- Account Data:
Retained for as long as your Account remains active. Following account closure or a verified deletion request, certain information may be retained where necessary to comply with legal, security, or contractual obligations.
- Transaction Data:
Retained for up to seven (7) years, or longer where required, to comply with applicable tax, accounting, and financial record-keeping obligations.
- Verification and Compliance Data:
Where identity verification or risk assessment data is collected, such information is retained only for the period required under applicable laws, fraud prevention standards, or dispute resolution needs, after which it is securely deleted or anonymized.
Users may submit a request for deletion of personal data through the privacy tools available on the Platform. Please note that certain information cannot be erased immediately where retention is required by law, for the establishment or defence of legal claims, or for the prevention of fraud and misuse.
6. Sharing with Third Parties
Redeemso International B.V. does not sell personal data. We may share personal data with carefully selected third parties where necessary to operate the Platform, provide Services, comply with legal obligations, or maintain Platform integrity.
Such third parties may include:
- • Payment Service Providers responsible for processing transactions and payment verification;
- • Fraud Prevention, Risk Monitoring, and Identity Verification Services used to detect abuse, enforce compliance requirements, and maintain platform security;
- • IT, Cloud Hosting, and Infrastructure Providers supporting the technical operation of the Platform;
- • Customer Support and Communication Tools used to manage support requests and user interactions;
- • Technical and Provisioning Partners involved in the delivery of Digital Content, including connectivity-related services such as eSIM activation.
All third-party service providers act on behalf of Redeemso International B.V. under appropriate contractual safeguards, including Data Processing Agreements (DPAs), and are required to process personal data in accordance with applicable data protection laws.
7. International Transfers
While we are based in the Netherlands, some of our service providers may process data outside the European Economic Area (EEA). In such cases, we ensure appropriate safeguards are in place, such as EU Commission Adequacy Decisions or Standard Contractual Clauses (SCCs), to protect your privacy rights.
8. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right to access your data
- Right to rectification (correction)
- Right to erasure ("Right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent
To exercise any of these rights, please submit a request via our Contact page or email our Data Protection Officer at privacy@redeemso.com.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We encourage you to review this page periodically. The "Last updated" date at the top of this policy indicates when the latest revisions were made.