Privacy Policy

1. Who we are

UNCLELINK ("UNCLELINK", "we", "us", "our") is operated by UNCLE GROUP LIMITED, a company incorporated in Hong Kong SAR. For the purposes of applicable data-protection law, UNCLE GROUP LIMITED is the controller of the personal data described in this Privacy Policy.

This Policy explains what personal data we collect when you browse our websites, create an account, install an eSIM, or buy an eSIM data plan; how and why we use it; who we share it with; how long we keep it; and the rights you have. It applies to the UNCLELINK app and the website at unclelink.com (together, the "Services").

2. Information we collect

• Account information — the email address and display name you provide when you register or check out, and a securely hashed form of your password. We never store your password in readable form.
• Sign-in with Apple / Google — if you choose social sign-in, we receive the verified email address, the name you share, and the provider's stable user identifier, used only to create or match your account.
• Order and payment records — the plans you buy, order numbers, amounts, currency and payment status. Card and other payment-instrument details are entered directly into, and processed by, our payment processor (Stripe); we do not see or store your full card number.
• eSIM and usage identifiers — the identifiers needed to provision and deliver your eSIM (such as the ICCID and activation details), together with the plan's validity, status and the usage data reported to us by our connectivity partners.
• Device-compatibility information — to help you check whether your device supports eSIM, the app may read your device model on the device itself. This check runs locally and is not used to track you.
• Technical and log data — information your device or browser sends automatically, such as IP address, device and browser type, and app/diagnostic events, which we use to operate the Services, keep them secure and prevent abuse.
• Rewards activity — information relating to the referral programme, 知音券 store credit and discount codes, such as referrals, balances and redemptions.
• Communications — messages you send us through support chat, contact forms or email.

3. How we collect it

We collect personal data directly from you (when you register, buy, install an eSIM, or contact us); automatically (through cookies, logs and in-app events); from the sign-in provider you choose (Apple or Google); and from our payment and connectivity partners (order, activation, usage and payment status needed to deliver and support your eSIM).

4. How we use your information

• To create and manage your account and verify you when you sign in.
• To process your orders and payments, and to provision, deliver and activate your eSIMs.
• To show your plan status and data usage, and to operate the referral, 知音券 credit and discount-code programmes.
• To provide customer support and respond to your enquiries.
• To send you service messages about your orders and account (such as order confirmations and eSIM delivery). These are not marketing.
• To operate, secure and improve the Services, and to detect, prevent and investigate fraud, abuse and security incidents.
• To comply with our legal, accounting and tax obligations, and to establish, exercise or defend legal claims.

5. Legal bases (EEA / UK users)

Where the EU or UK GDPR applies, we rely on: performance of a contract, to provide the account and eSIM you request; our legitimate interests, to secure, operate and improve the Services and to prevent fraud; your consent, for non-essential cookies and any optional marketing; and compliance with legal obligations, for accounting and tax records.

Where we rely on consent, you may withdraw it at any time without affecting processing carried out before withdrawal.

6. How we share your information

We do not sell your personal data. We share it only with service providers who process it on our behalf under contract, and only to the extent needed to run the Services:

• Payment processing — Stripe processes your payments and related transaction data.
• Connectivity partners — our network and eSIM partners receive the information needed to provision, activate and support your eSIM.
• Communications and support — providers that deliver transactional email, your eSIM details and support chat.
• Hosting and infrastructure — cloud and infrastructure providers that host the Services.
• Professional advisers, and authorities or other parties where disclosure is required by law, to enforce our terms, or to protect our rights, users or the public.
• In connection with a merger, acquisition or other business transfer, subject to this Policy.

7. International transfers

We operate from Hong Kong and work with partners in other regions, so your personal data may be processed outside the country where you live, including in Hong Kong. Where required, we put in place appropriate safeguards for such transfers.

8. Cookies and tracking

Our websites use cookies that are strictly necessary to run the site — for example, to keep you signed in and remember your consent choices — and, only with your consent, cookies that help us understand how the site is used. You can accept or decline non-essential cookies on your first visit and change your choice at any time. The UNCLELINK mobile app does not contain third-party advertising or cross-app tracking SDKs and does not track you across other companies' apps or websites.

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9. How long we keep your information

We keep your account data for as long as your account is active. We keep order, payment and eSIM records for as long as needed for accounting, tax, warranty and dispute-resolution purposes (which, under applicable law, may be up to seven years), after which we delete or anonymise them. When you delete your account, we remove or anonymise personal data that we are not required to retain.

10. How we protect your information

We use encryption in transit, encryption of sensitive data at rest, access controls on a need-to-know basis, and other technical and organisational measures appropriate to the risk. No method of transmission or storage is perfectly secure, but we work continuously to protect your information.

11. Children

The Services are intended for users aged 18 and over and are not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it.

12. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to data portability, and to withdraw consent. If you are in California, you may have the right to know, delete and correct your personal information, and to opt out of its "sale" or "sharing" — we do not sell or share personal information in that sense — and you will not be discriminated against for exercising these rights.

To exercise your rights, contact us at privacy@unclegroup.io. We may need to verify your identity before acting, and we will respond within the time required by applicable law. You may also lodge a complaint with your local data-protection authority.

13. Third-party links

The Services may link to third-party sites or services that we do not control. This Policy does not apply to them, and we are not responsible for their content or privacy practices. Please review their policies before providing personal data.

14. Changes to this Policy

We may update this Policy from time to time. The "last updated" date shows when it last changed, and the current version always applies to your use of the Services. Where changes are material, we will take reasonable steps to notify you.

15. Contact us

For any privacy question, or to exercise your rights, contact UNCLE GROUP LIMITED at privacy@unclegroup.io or info@unclegroup.io.