Privacy Policy

The short version

We collect the minimum needed to sell you a data plan and keep it working: who you are, what you bought, and how much data is left. We use Amplitude and Google Analytics to understand how the app is used, and the Meta SDK to measure which of our ads bring people in. On iPhone, Meta only gets your advertising identifier if you allow tracking when asked. We do not sell your data.

• We never see your password. You sign in with Google or Apple.
• We never see your full card number. Stripe handles payment.
• We cannot see what you browse, who you message, or the content of your traffic.
• We do not track your location. We know which destination you bought a plan for, which is not the same thing.
• You can delete your account from Settings in the app at any time.

The rest of this page is the detail behind those statements. It is long because being specific is the only way to be honest about data.

1. Who is responsible for your data

Innovage.io LLC, a limited liability company registered in Wyoming, United States, is the controller of the personal data described in this policy. You can reach our privacy contact at esim@innovage.io.

This policy covers the Inovo eSIM mobile app, our website at esim.innovage.io, and the support we provide around them.

2. What we collect

We collect seven kinds of data, and nothing else.

Account data

Your email address, your display name, which provider you signed in with (Google or Apple), and your notification preferences. We receive the first three from Google or Apple when you sign in. We store an internal user id and the sign in provider's user id so we can recognise you next time. We never receive or store your Google or Apple password.

Purchase data

The plans you bought, the destinations they cover, the price you paid, the order status, the time of purchase, whether the order was refunded and why, the record of any payment dispute or chargeback raised against it, and a Stripe customer id that links your account to your payment records inside Stripe. We do not store your card number, expiry, or security code. Stripe holds those, and we only ever receive a token and the last four digits for display.

eSIM and usage data

For each eSIM you own: its ICCID (the identifier of the SIM profile), its activation code and QR code, its current lifecycle status, its total allowance, how many bytes have been used, and when it activates and expires. We take periodic snapshots of the used byte count so the app can show you a usage history and warn you before you run out.

Device and notification data

If you enable push notifications we store the push token your device gives us, your platform (iOS or Android), and your device model, such as iPhone 16, so we can tell you which device a notification will go to. We do not collect the name you have given your device. We store a log of which service notifications we have already sent, so we do not send the same one twice.

Referral and credit data

If you use the refer a friend program: your invite code, who invited you or whom you invited, whether a reward was earned, and the account credit you earned, spent or lost. To stop people referring themselves we also store your phone's app identifier (on iPhone the identifier Apple gives our apps, on Android the Android ID) when you open the invite screen or check out, and a fingerprint of the payment card that Stripe provides, which identifies a card without revealing its number. These are used only to check referrals and are never used for advertising.

Support data

The emails you send us and our replies. While helping you, our team can add short internal notes to your account, and we record account flags such as a hold on purchases while we look into suspected fraud.

App usage data

What you do in the app, recorded as events: for example opening a destination, viewing a plan, starting checkout, completing or cancelling a payment, installing or activating an eSIM, or opening a setup guide. Each event carries plan facts such as the plan, its price and length, plus your app version, device model, operating system, language, country, a random identifier for your install and your internal account id. It never includes your email, name, card details, ICCID or activation code. If you allow tracking on iPhone, or have not turned off ad personalisation on Android, Meta also receives your device advertising identifier.

Technical data

When the app or website talks to our servers, our hosting and logging providers record standard request information: IP address, user agent, the address requested, the time, the response, and any error. An error record can include an internal account or order id. We use this to keep the service running, find faults and stop attacks, and never to track you.

3. Location, stated precisely

The Inovo eSIM app does not request location permission and does not collect GPS, Wi-Fi or Bluetooth location from your device.

What we do know is inferred, and only at country level. If you buy a Japan plan and it activates, we know an eSIM registered on a Japanese network. That is a necessary consequence of selling you connectivity in a country, and it is the same thing your own carrier knows when you roam.

Separately, the mobile network operator delivering your connectivity knows the location of the cell towers your device connects to, because that is how cellular networks function. That data is held by the carrier under its own law and privacy policy, not by us, and we do not receive it.

Our payment processor also uses the IP address of your device at checkout for fraud scoring. We see the country and risk score that produces, not a location trail.

4. Why we use it, and our legal basis

Where the GDPR or UK GDPR applies to you, we must have a legal basis for each use. Here is every purpose, and its basis.

Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights, and concluded it is not, because the processing is limited to what the service needs and we do not build advertising profiles of you. Ad measurement through Meta follows the choice you make in your device tracking settings. You can object to any of it at any time. See section 9.

5. What we do not do

Stating this positively is more useful than a list of exceptions, so here it is in plain terms.

• We do not sell your personal information, and we never have.
• We share app events with Meta only to measure our own ads. We do not show ads in the app, and we do not let anyone else advertise to you through it.
• We do not run session replay or crash reporting SDKs, and we do not record your screen or what you type.
• We do not build advertising profiles or infer sensitive characteristics about you.
• We do not inspect, log, or retain the content of your internet traffic. We could not do so even if we wanted to.
• We do not use your data to train machine learning models.
• We do not buy personal data about you from data brokers.

6. Who we share it with

We share personal data only with the service providers that make Inovo eSIM work, only to the extent they need it, and only under contracts that require them to protect it and forbid them from using it for their own purposes. Here is the complete list.

Beyond that list, we disclose personal data only in these situations.

• When the law requires it, such as a valid subpoena, court order or lawful request from a public authority. We check that every request is valid and narrow before responding, and we tell you unless we are legally barred from doing so.
• To establish, exercise or defend a legal claim, including responding to a payment dispute you raised with your bank.
• To protect the rights, property or safety of you, of us, or of the public, including preventing fraud.
• To a buyer or successor if the business is sold, merged or reorganised. Your data stays subject to this policy, and we will notify you before it becomes subject to a different one.

7. Where your data goes

We are a United States company and our infrastructure is primarily in the United States. If you are in the European Economic Area, the United Kingdom or Switzerland, using Inovo eSIM means your personal data is transferred to the United States and to the providers listed in section 6.

For those transfers we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum where applicable, and our providers' own certifications under the EU-US Data Privacy Framework where they hold one. You can ask us for a copy of the safeguards we rely on by writing to esim@innovage.io.

Delivering connectivity is inherently international. When you use a plan abroad, the local carrier processes network data in that country under its own law. We cannot change that, and it is a normal part of how roaming works.

8. How long we keep it

We keep data only as long as we need it for the purpose we collected it, or as long as the law requires.

When you delete your account we immediately delete your sign in identity at Google or Apple's end through Firebase, delete every push token so notifications stop at once, delete the device identifiers kept for referral checks, and remove your email address and display name from your account record. What remains is an internal id that cannot be signed into, kept only to tie your past orders together for the financial records described below.

We keep your order and payment records for 7 years after deletion because tax, accounting and anti money laundering rules require us to, and because a refund or chargeback can arrive months after a purchase. Those retained records are financial records, kept for that purpose only, and are not used to market to you or to rebuild a profile of you.

9. Your rights

Wherever you live, you can ask us to do any of the following, and we will honour it unless the law requires us to keep something. Write to esim@innovage.io and we will respond within 30 days.

Access

Get a copy of the personal data we hold about you, and be told what we do with it.

Correction

Have inaccurate data fixed. Most account details you can edit yourself in the app.

Deletion

Have your data erased. You can do this yourself in Settings, and section 8 explains what we must keep.

Portability

Receive your data in a structured, machine readable format, or have us send it to another controller where that is technically feasible.

Restriction

Ask us to pause processing while a dispute about accuracy or legitimacy is resolved.

Objection

Object to processing based on legitimate interests, including any profiling. We will stop unless we have compelling grounds that override your rights.

Withdraw consent

Where we rely on consent, withdraw it at any time. This does not affect processing that already happened.

Complain

Lodge a complaint with your data protection authority. In the EU that is the authority where you live or work. In the UK it is the Information Commissioner's Office. We would rather you told us first, but you do not have to.

We do not charge for this, and we will not treat you differently for exercising a right. We may ask you to verify your identity before acting on a request, because handing your data to the wrong person would be a far worse outcome than a small delay.

There is no automated decision making that produces a legal or similarly significant effect on you. Our fraud checks can hold or decline an order, and you can always reach a human at esim@innovage.io to have that reviewed.

10. United States state privacy rights

If you live in California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana or another state with a comprehensive privacy law, you have the rights in section 9, and they apply to you regardless of which state you live in. We extend them to everyone rather than gating them by geography.

For California residents specifically, under the CCPA as amended by the CPRA: in the past 12 months we collected the categories of personal information described in section 2, being identifiers, commercial information, internet or network activity limited to byte counts and in app usage events, and inferences limited to the destinations you shop for. We collected them from you and from our sign in and payment providers, for the purposes in section 4, and disclosed them only to the providers in section 6.

We have never sold personal information. We share limited app event data and, with your permission, your advertising identifier with Meta to measure our ads, which California law may treat as sharing for cross context behavioural advertising. You can opt out at any time: decline the tracking prompt or turn tracking off in your iPhone settings under Privacy and Security, Tracking; turn off ad personalisation in your Android settings; or email esim@innovage.io and we will stop sending your events to Meta. We also honour Global Privacy Control signals on our website.

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you, so the right to limit its use does not arise. You may designate an authorised agent to make a request on your behalf, with proof of authorisation.

11. How we protect it

Security is a practice rather than a promise, and no system is perfectly safe. These are the specific measures we take.

• All traffic between your device, our API and our providers is encrypted in transit with TLS.
• Data at rest in our database is encrypted by our hosting provider.
• Our database is not reachable from the public internet. Only our API can query it, using a credential that is never shipped in the app.
• The app never holds a database credential or a payment secret. It holds only a short lived sign in token.
• Payment card data never touches our servers. It goes from your device to Stripe directly.
• Administrative access is limited to named people with individual accounts and defined roles, and every administrative action against a user record is written to an audit log.
• Sensitive actions such as deleting your account require a freshly verified sign in token, so a stolen stale token cannot trigger them.
• Payment and supplier webhooks are cryptographically verified before we act on them, and replayed events are ignored.

If a breach occurs that is likely to result in a risk to your rights, we will notify the relevant supervisory authority within 72 hours where the law requires it, and we will tell you directly and without undue delay where the risk to you is high.

12. Children

Inovo eSIM is not for children. You must be at least 18 to have an account, because you must be able to enter a contract and pay for a plan. We do not knowingly collect personal data from anyone under 18, and the app carries no content directed at children.

If you believe a child has given us personal data, write to esim@innovage.io and we will delete it promptly.

13. Cookies and similar technologies

The app uses no cookies. It stores a sign in token and your language preference on your device. Its analytics tools, Amplitude and Google Analytics for Firebase, store a random identifier for your install. Meta's SDK reads your device advertising identifier only if you allow tracking, and you can change that at any time in your device settings.

The Cookie Notice covers what our website uses, which is very little. Read the Cookie Notice.

14. Changes to this policy

When we change this policy we update the version and dates at the top. If a change materially affects how we use your data, we will tell you in the app or by email before it takes effect, and where the law requires consent we will ask for it rather than assume it.

We keep previous versions and will provide one on request, so you can see exactly what changed and when.

15. Contact us

For any privacy question or request, write to esim@innovage.io. For everything else, esim@innovage.io reaches us faster.

Innovage.io LLC, registered in Wyoming, United States.