Privacy policy

This Privacy Notice for 1Locol Technologies LTD (doing business as 1Locol) ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

• Visit our website at https://1locol.com or any website of ours that links to this Privacy Notice
• Browse, purchase, receive, or manage eSIM connectivity through the 1Locol website or, where available, the mobile application.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@1locol.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not intentionally collect special-category or biometric information as part of purchasing or providing our current eSIM services. Please do not send this information to us unless it is necessary for a support request and we ask you to provide it.

Do we collect any information from third parties? Yes. We may receive personal information from service providers and partners that help us provide our Services, including payment processors, fraud-prevention providers, eSIM and connectivity providers, mobile network operators, and other service providers. The information we receive depends on the service being used and may include payment status, transaction information, technical information, eSIM activation or usage information, and fraud or security signals.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by emailing privacy@1locol.com, or by contacting us using the details in this notice. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

eSIM AND CONNECTIVITY SERVICES

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us and, where necessary to provide our Services, information received from service providers and partners.

We collect personal information that you voluntarily provide to us when you register for the Services, purchase a product or service, express an interest in obtaining information about us or our products and Services, participate in activities through the Services, or otherwise contact us.

Personal Information Provided by You

The personal information we collect depends on how you interact with us, the products and features you use, and the choices you make. This may include:

• name;
• phone number;
• email address;
• username;
• password or authentication credentials;
• contact preferences;
• billing address;
• order and transaction information;
• eSIM plan and destination information;
• customer support communications.

Sensitive Information

We do not intentionally collect special-category information, biometric data, identity documents, or national identification numbers as part of purchasing or providing our current eSIM services. If information of this kind is voluntarily included in a support communication, we will handle it only as necessary to address the request and in accordance with applicable law.

Payment Data

When you make a payment, payment card information is collected and processed by our payment service provider, currently Stripe.

1Locol does not directly store your full payment card number or card security code.

We may receive and retain payment-related information such as:

• payment status;
• transaction amount;
• currency;
• payment method type;
• payment provider reference;
• limited card information such as card brand and last four digits, where provided by the payment processor;
• refund status; and
• dispute or chargeback information.

Stripe's privacy notice is available at https://stripe.com/ie/privacy.

Information Received From Third Parties

We may receive personal information from third parties where necessary to operate and protect our Services.

These may include:

• payment service providers;
• fraud-prevention and security providers;
• eSIM and connectivity providers;
• mobile network operators and roaming partners;
• authentication and communications providers; and
• other service providers involved in delivering a product or service you request.

Depending on the service, information received may include:

• payment and transaction status;
• fraud and security signals;
• eSIM identifiers;
• activation and installation status;
• network and connectivity information;
• data usage information;
• technical diagnostic information; and
• service fulfilment status.

We only use information received from third parties for purposes consistent with this Privacy Notice and applicable law.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Certain technical, device, usage, network, and location information may be collected automatically when you use our Services.

We automatically collect certain information when you visit, access, or use our Services. Depending on the product or feature being used, this may include:

• IP address;
• browser and device characteristics;
• device identifiers;
• operating system;
• language preferences;
• referring URLs;
• device name;
• country;
• approximate or precise location where enabled;
• application activity;
• dates and times of access;
• diagnostic and error information;
• mobile carrier information; and
• network and connection information.

This information is primarily used to operate, secure, troubleshoot, analyse, and improve our Services.

Analytics Data

We use Vercel Web Analytics to understand aggregated usage of our website and application, including information such as page views, device type, browser, operating system, referrer, and approximate geographic information.

Vercel Web Analytics does not use cookies and is designed to provide privacy-focused, aggregated analytics without requiring persistent identifiers to track individual users across browsing sessions.

We use this information to understand how our Services are used, monitor performance, identify usage trends, and improve the user experience.

eSIM and Connectivity Services

When you purchase or use an eSIM through 1Locol, we process certain personal data to complete your purchase, deliver your eSIM, provide connectivity, manage your order, prevent fraud, and provide customer support.

Information Collected When You Purchase an eSIM

When you purchase an eSIM, we may collect:

• your email address;
• order and transaction details;
• the eSIM plan or destination selected;
• purchase date and order identifier;
• payment status and payment-related reference information; and
• information you provide when contacting customer support.

We use this information to:

• process and confirm your order;
• deliver your eSIM and installation instructions;
• send purchase receipts and service-related communications;
• provide customer support;
• manage refunds, disputes, and service issues;
• maintain transaction and accounting records; and
• prevent fraud and misuse.

Your full payment card details are processed by our payment service provider and are not stored directly by 1Locol.

We do not routinely provide your email address to mobile network operators solely for network connectivity unless it is necessary for service provision or support, required by law, or otherwise disclosed to you.

Technical and Connectivity Information

To provide and operate your eSIM, certain technical information may be processed by or shared with our eSIM service providers, mobile network operators, and roaming partners.

Depending on the service, this information may include:

• device type, model, and operating system;
• device compatibility information;
• eSIM identifiers, including ICCID or similar identifiers;
• network and connection information;
• IP address;
• mobile network information;
• activation and installation status;
• data usage and consumption information;
• country or network from which the service is accessed; and
• technical diagnostic information required to provide or troubleshoot the service.

This information may constitute personal data even where it does not directly identify you by name.

Why We Process eSIM Information

We primarily process information relating to the purchase, delivery, activation, and operation of an eSIM where it is necessary to:

• perform our contract with you and provide the service you requested;
• operate, secure, and troubleshoot our Services;
• prevent fraud, abuse, and misuse;
• maintain appropriate business and transaction records; and
• comply with applicable legal or regulatory requirements.

Where we rely on legitimate interests, we do so only where those interests are not overridden by your rights and freedoms.

Who Receives eSIM Information

Depending on the service, relevant information may be shared with:

• payment service providers involved in processing your purchase;
• eSIM technology and connectivity providers;
• mobile network operators;
• roaming partners; and
• technical providers involved in operating or supporting the connectivity service.

We limit disclosure to information reasonably necessary for the recipient to perform its role.

Technical and connectivity information may be processed outside the European Economic Area where this is necessary to provide international connectivity. Where applicable, international transfers of personal data are made in accordance with applicable data protection law and appropriate transfer safeguards.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
• To provide eSIM and connectivity services. We may process order, device, network, activation, usage, and technical information to provision, operate, manage, and support eSIM connectivity.
• To prevent fraud, abuse, and unauthorised activity. We may process transaction, account, device, payment, identity, network, and behavioural information to detect and prevent fraud, misuse, security incidents, and other prohibited activity.
• To maintain financial, tax, and transaction records. We may retain information where necessary for accounting, taxation, dispute management, fraud prevention, audit, and other legal or business record-keeping purposes.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services
• Analyse how our Services are used so we can improve them to engage and retain users
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share personal information with service providers and other recipients where necessary to provide our Services, operate our business, comply with legal obligations, or protect our Services and users.

We use third parties to provide infrastructure, payments, communications, connectivity, fraud prevention, analytics, and other services.

The role of each third party may differ. Some providers process personal information on our instructions as processors, while others may process information as independent or joint controllerswhere they determine certain purposes or means of processing themselves or are subject to their own legal or regulatory obligations.

Where required, we enter into appropriate contractual and data-protection arrangements with third parties.

The categories of recipients may include:

Cloud Computing and Infrastructure

• Vercel
• database, API-hosting, and infrastructure providers;

Communications

• transactional-email and customer-communications providers;

Payment Processing

• Stripe

Fraud Prevention and Security

• fraud-prevention and security providers.

eSIM and Connectivity Services

• eSIM technology providers;
• connectivity service providers;
• mobile network operators; and
• roaming partners.

These providers may receive or process technical and connectivity information necessary to provision and operate an eSIM.

Analytics

• Vercel Analytics

Hosting

• Vercel
• Fly.io

Application and Performance Monitoring

• Sentry

We may also share personal information in the following circumstances:

Business Transfers

We may disclose or transfer information in connection with, or during negotiations concerning, a merger, financing, acquisition, corporate reorganisation, sale of assets, or similar transaction.

Legal and Regulatory Requirements

We may disclose information where reasonably necessary to comply with applicable law, regulation, court order, legal process, law-enforcement request, regulatory requirement, or to establish, exercise, or defend legal claims.

Protecting Rights and Security

We may disclose information where reasonably necessary to investigate fraud, abuse, security threats, prohibited activity, or threats to the rights, property, or safety of 1Locol, our users, our partners, or others.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: Yes. Because 1Locol provides global travel, payment, and connectivity services, personal information may be processed outside the country in which you reside.

Our infrastructure and service providers may process information in Ireland, the United Kingdom, the United States, the European Economic Area, and other jurisdictions.

In particular, international eSIM and mobile connectivity services may require certain technical and connectivity information to be processed by mobile network operators, roaming partners, or connectivity providers in the country where you use the service or through which connectivity is routed.

Where personal data originating in the EEA is transferred to a country that has not been recognised by the European Commission as providing an adequate level of protection, we use an applicable lawful transfer mechanism where required, which may include:

• European Commission Standard Contractual Clauses;
• adequacy decisions;
• other legally recognised transfer mechanisms; or
• an applicable derogation permitted under data protection law.

Additional information about relevant transfer safeguards may be requested by contacting privacy@1locol.com.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including where longer retention is required or permitted for legal, regulatory, accounting, tax, fraud-prevention, dispute, or compliance purposes.

The appropriate retention period depends on the nature of the information and why it is being processed.

For example, we may retain:

• account information while your account remains active and for an appropriate period following closure;
• order, payment, refund, and transaction records for the period necessary to satisfy accounting, taxation, audit, dispute, and legal requirements;
• fraud and security records where reasonably necessary to prevent repeated fraud, misuse, or security incidents;
• eSIM order and service records for the period reasonably necessary to provide support, manage disputes, analyse service delivery, and comply with legal obligations; and
• customer-support records for the period reasonably necessary to resolve requests and maintain appropriate business records.

We do not apply a universal twelve-month deletion period where a longer period is necessary or required.

When we no longer have a lawful or legitimate reason to retain personal information, we will delete or anonymise it. Where immediate deletion is not technically possible, such as information held in secure backup archives, we will protect and restrict further processing until deletion occurs in accordance with our retention procedures.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@1locol.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

• Email: privacy@1locol.com
• Post: See 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

What happens after you complain

• We will acknowledge your complaint within 30 days of receiving it.
• We will investigate without unjustifiable or excessive delay.
• We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Ireland, you also have the right to lodge a complaint with the Data Protection Commission (DPC), Ireland's supervisory authority for data protection.

You may contact the DPC through its official website at www.dataprotection.ie.

You are not required to contact us before exercising your right to lodge a complaint with a supervisory authority, although we welcome the opportunity to address your concerns directly.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at privacy@1locol.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section 'WHAT INFORMATION DO WE COLLECT?'

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can email us at privacy@1locol.com, or use the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@1locol.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, contact our privacy team by email at privacy@1locol.com, or contact us by post at:

1Locol Technologies LTD

Privacy Team

69 The Junction
The Crossings
Lucan, Co. Dublin
Ireland
K78 T6W8

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email privacy@1locol.com.