Privacy Policy

Last Updated: November 20, 2025

Your Privacy Matters

Elites eSIM Platform ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our telecommunications services, eSIM platform, GSM services, and related technologies.

Table of Contents

1. Information We Collect

1.1 Personal Information

When you register for our services or use our platform, we collect:

  • Account Information: Name, email address, phone number, billing address, and payment information
  • Identity Verification: Government-issued ID, date of birth, and other KYC (Know Your Customer) documentation as required by telecommunications regulations
  • Business Information: Company name, business registration number, tax ID (for enterprise customers)

1.2 Device Information

We collect information about the devices you use to access our services:

  • Device Identifiers: IMEI (International Mobile Equipment Identity), EID (eSIM Identifier), ICCID (Integrated Circuit Card Identifier)
  • Device Details: Device make, model, operating system, browser type, and version
  • Network Information: IP address, MAC address, mobile network operator

2. Telecommunications and GSM Data

Telecommunications Data Collection

As a telecommunications service provider, we collect and process various types of communications data to provide, maintain, and improve our services. This data is essential for network operation and billing purposes.

2.1 Call and Messaging Data

  • Call Detail Records (CDRs): Date, time, duration, calling and called numbers (we do not record call content)
  • SMS Records: Message metadata including sender, recipient, timestamp, and message routing information
  • MMS Data: Multimedia message metadata and delivery confirmations

2.2 Data Usage and Network Information

  • Data Session Records: Volume of data transmitted and received, session start/end times, data plan usage
  • Network Performance: Signal strength, connection speed, network latency, tower/cell information
  • Roaming Information: Visited networks, roaming countries, international usage data

2.3 Location Data

  • Network-Based Location: Cell tower triangulation data used for network operations and emergency services
  • GPS Location: Precise location data (only with your explicit consent for location-based services)
  • Country/Region Data: General geographic location for service provisioning and fraud prevention

2.4 eSIM and Profile Management

  • eSIM Activation Data: QR code scans, activation timestamps, profile downloads
  • Profile Status: Active, inactive, suspended, or deleted eSIM profiles
  • Carrier Integration: Carrier switching events, network preferences, MVNO operations data

3. Platform Usage and Technical Data

3.1 Usage Analytics

  • Platform Activity: Login times, features used, pages viewed, time spent on platform
  • Transaction History: Purchase records, payment methods, order history, refund requests
  • Support Interactions: Customer support tickets, chat logs, email correspondence

3.2 Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

  • Essential Cookies: Required for platform functionality and security
  • Performance Cookies: Analytics to improve service quality
  • Functional Cookies: Remember your preferences and settings
  • Marketing Cookies: Deliver relevant advertisements (with your consent)
IPTV/OTT TV Streaming

4. IPTV/OTT TV White Label Portal & Management Data

Streaming Media Services and Content Privacy

Our IPTV/OTT TV platform collects and processes specific data to deliver streaming media services, manage subscriptions, and ensure content security. We are committed to protecting your viewing privacy and content consumption data in accordance with applicable privacy laws and industry standards.

4.1 Streaming and Viewing Data

  • Content Consumption: Titles watched, viewing duration, playback progress, watch history, viewing frequency, content preferences and recommendations data
  • Streaming Quality Data: Video resolution selected, bitrate adaptation, buffering events, connection speed, device capabilities, network performance metrics
  • Interactive Features: Search queries, content ratings and reviews, favorites and watchlists, parental control settings, subtitle and audio preferences

4.2 Subscription and Account Management

  • Subscription Information: Plan type (PAYW, daily, weekly, monthly, quarterly, yearly), payment history, billing cycles, subscription start/end dates, auto-renewal preferences, promotional codes used
  • Portal Access Data: Login credentials (encrypted), session information, multi-device login tracking, concurrent stream management, access timestamps and IP addresses
  • Profile Management: User profile information, household member profiles, viewing restrictions and parental controls, language and region preferences, accessibility settings

4.3 Content Delivery and DRM Data

  • Digital Rights Management: DRM license requests, content encryption keys (securely managed), device authentication tokens, playback authorization logs, geo-blocking enforcement data
  • CDN and Delivery Metrics: Content delivery network routing, edge server locations, bandwidth consumption, streaming protocols used (HLS, DASH), cache hit rates
  • Anti-Piracy Measures: Forensic watermarking (where applicable), screen capture detection, unauthorized sharing prevention, HDCP compliance verification

4.4 White Label Portal Data

  • Super Admin Data: Content management activities, user administration logs, billing configuration changes, system settings modifications, analytics access patterns
  • Sub-Super Admin & Reseller Data: Regional content preferences, subscriber management activities, commission tracking, white-label customization settings, business performance metrics
  • Customer Portal Data: Content browsing behavior, search patterns, recommendation interactions, customer support inquiries, payment method information

4.5 How We Use IPTV/OTT Data

We use streaming platform data for the following purposes:

  • • Deliver streaming content with optimal quality and minimal buffering
  • • Personalize content recommendations based on viewing preferences
  • • Manage subscriptions, billing, and payment processing
  • • Enforce content licensing agreements and geographic restrictions
  • • Prevent unauthorized access and piracy
  • • Improve platform performance and user experience
  • • Provide customer support and troubleshooting
  • • Generate analytics for content providers and licensors
  • • Comply with content licensing and regulatory requirements

Viewing Privacy Notice

We do not sell your viewing history or content preferences to third parties. Viewing data is shared only with content licensors as required by licensing agreements, and in aggregated, anonymized form for analytics purposes. You can request deletion of your viewing history at any time through your account settings.

5. How We Use Your Information

We use your information for the following purposes:

Service Delivery and Operations

  • • Provision and activate telecommunications services
  • • Process eSIM activations and manage profiles
  • • Route calls, messages, and data traffic
  • • Monitor network performance and service quality
  • • Provide customer support and troubleshooting

Billing and Financial Management

  • • Generate accurate bills based on usage
  • • Process payments and manage accounts
  • • Detect and prevent fraudulent activities
  • • Manage subscriptions and renewals

Regulatory Compliance

  • • Comply with telecommunications regulations
  • • Fulfill lawful interception requirements
  • • Maintain records as required by law
  • • Support emergency services (E911/E112)
  • • Prevent illegal activities and abuse

Service Improvement and Innovation

  • • Analyze usage patterns to improve services
  • • Develop new features and capabilities
  • • Optimize network performance
  • • Conduct research and analytics

Marketing and Communications

  • • Send service updates and notifications
  • • Provide promotional offers (with consent)
  • • Conduct surveys and gather feedback
  • • Send newsletters and product information

6. Data Sharing and Disclosure

We may share your information with:

Network Operators and Carriers

We share necessary information with mobile network operators, MVNO partners, and carrier aggregators to provide telecommunications services, enable roaming, and process network operations.

Service Providers and Partners

Third-party service providers who assist with payment processing, fraud detection, customer support, cloud infrastructure, analytics, and marketing (under strict data protection agreements).

Regulatory and Law Enforcement

When required by law, we disclose information to government authorities, regulatory bodies, and law enforcement agencies in response to valid legal requests, court orders, or to protect our rights and comply with legal obligations.

Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

With Your Consent

We may share your information with other parties when you provide explicit consent for specific purposes.

7. Data Security

Enterprise-Grade Security

We implement industry-leading security measures to protect your personal and telecommunications data from unauthorized access, disclosure, alteration, or destruction.

Technical Security Measures:

  • • End-to-end encryption for data transmission (TLS 1.3)
  • • Encrypted storage of sensitive data at rest (AES-256)
  • • Multi-factor authentication (MFA) for account access
  • • Regular security audits and penetration testing
  • • Intrusion detection and prevention systems
  • • Network segmentation and access controls
  • • Secure eSIM profile provisioning protocols

Organizational Security Measures:

  • • Employee training on data protection and privacy
  • • Strict access controls and least privilege principles
  • • Background checks for personnel with data access
  • • Incident response and breach notification procedures
  • • Regular security policy reviews and updates

8. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this policy and to comply with legal obligations:

Account Information

Active account duration + 7 years after account closure

Active + 7 years

Call Detail Records (CDRs)

Retained for 2-7 years per telecommunications regulations

2-7 years

Billing and Transaction Records

Minimum 7 years for tax and accounting purposes

7+ years

Platform Usage and Analytics

Aggregated data retained indefinitely; personal data 2 years

2 years

Marketing Communications

Until consent withdrawn or 3 years of inactivity

Until opt-out

9. Your Privacy Rights

Depending on your jurisdiction, you have the following rights regarding your personal information:

Right to Access

Request a copy of the personal data we hold about you, including telecommunications usage records.

Right to Correction

Update or correct inaccurate or incomplete personal information.

Right to Deletion

Request deletion of your personal data (subject to legal retention requirements).

Right to Portability

Receive your data in a structured, machine-readable format and transfer to another provider.

Right to Restrict Processing

Limit how we process your personal data in certain circumstances.

Right to Object

Object to processing of your data for direct marketing or other purposes.

Right to Withdraw Consent

Withdraw consent for processing where we rely on consent as the legal basis.

Right to Lodge a Complaint

File a complaint with your local data protection authority.

How to Exercise Your Rights

To exercise any of these rights, please contact our Privacy Team at:

We will respond to your request within 30 days. Identity verification may be required to protect your privacy.

10. International Data Transfers

As a global telecommunications platform operating in 230+ countries, your information may be transferred to, stored, and processed in countries outside your residence, including countries that may have different data protection standards.

Data Transfer Safeguards

  • • Standard Contractual Clauses (SCCs) approved by regulatory authorities
  • • Adequacy decisions where applicable (e.g., EU-US Data Privacy Framework)
  • • Binding Corporate Rules for intra-group transfers
  • • Encryption during transit and at rest
  • • Compliance with GDPR Chapter V requirements

Roaming and International Operations

When you use our services while roaming internationally, your data will be processed by local network operators in those countries. We require our roaming partners to maintain appropriate data protection standards through contractual agreements.

11. Children's Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18 without parental consent.

If you are a parent or guardian and believe your child has provided personal information to us, please contact us immediately. We will take steps to delete such information from our systems.

For accounts created for minors (13-17 years old), parental or guardian consent is required, and additional restrictions may apply in accordance with local laws (e.g., COPPA in the United States).

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. We will notify you of any material changes through:

  • • Email notification to your registered email address
  • • Prominent notice on our platform homepage
  • • In-app notification upon your next login
  • • SMS notification for significant changes

The "Last Updated" date at the top of this policy indicates when it was last revised. Your continued use of our services after changes become effective constitutes acceptance of the revised policy.

We encourage you to review this policy periodically to stay informed about how we protect your information.

13. Contact Us

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

Privacy Team

Phone:

Sales & Support Phone Numbers - Coming Soon

Response Time:

Within 30 days

Data Protection Officer

Postal Address:

Elites eSIM Platform
Phone System Global Inc.
5411-F Backlick Road,
Springfield, VA 22151

Regulatory Compliance

Our privacy practices comply with applicable data protection and telecommunications regulations, including:

GDPR

EU General Data Protection Regulation

CCPA/CPRA

California Privacy Rights Act

TCPA

Telephone Consumer Protection Act

ePrivacy

EU ePrivacy Directive

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