Privacy Policy

Your privacy is important to us. This Privacy Policy explains what personal data

Qonnect (Neovation Technologies LLC) collects from users, how we use and protect

that data, and what rights you have regarding your information. This policy applies to

information collected through our website, mobile app, and eSIM services. By using

Qonnect, you agree to the collection and use of information as described in this

1. Data Controller: Neovation Technologies LLC (operating under the brand

"Qonnect"), a company registered in the State of New Mexico, USA, is the data

controller for personal information collected in connection with Qonnect services. If

you have any questions or requests regarding your personal data, you can contact

us at support@qonnect.com or at our business address provided in the Legal Notice

section below.

2. Information We Collect: We may collect and process the following categories of

personal data:

• Account and Contact Information: When you create an account or make a

purchase, we collect information such as your name, email address, phone

number, mailing/billing address, and password. If you contact support, we

may also collect your contact details and any information you provide in your

inquiry.

• Payment Information: If you purchase an eSIM, our third-party payment

processor (e.g., Stripe) will collect your payment card details. We receive

limited payment information such as a transaction ID, card type (Visa, etc.),

last four digits of the card, and payment status, but we do not store full credit

card numbers or security codes on our servers.

• Device and Technical Information: When you use our website or app, we

automatically collect technical information such as your device type, operating

system, browser type, IP address, unique device identifiers, and app version.

If you install our eSIM, we may collect device-specific identifiers necessary for

activating the eSIM (for example, your device’s eSIM EID or IMEI and device

model, as needed to deliver the eSIM profile).

• Service Usage Data: We collect information about your use of the eSIM

service, including data usage (amount of data consumed), the countries or

regions where the service is used, timestamps of connections, and network

information. We may also log events like successful installation or any errors

in activation for troubleshooting.

• Cookies and Similar Technologies: When you visit our website or use the

app, we use cookies and similar tracking technologies (see our Cookie Policy

below) to collect information about your browsing actions and preferences.

This can include your interactions on our site, pages viewed, and referral

URLs.

• Location Information: We do not continuously track your precise GPS

location; however, when you use the eSIM, we can infer general location

(country or city level) based on the network you connect to (e.g., if you use

data in France, we know the service was used in France). Our mobile app, ifused, might request your permission for location purely to offer localized

services (for example, to show available plans for your region), but that would

be optional and based on consent.

• Communications: If you subscribe to a newsletter or opt in to marketing, we

will collect your email for that purpose. We also keep records of our

communications with you, such as support emails or chat transcripts, to better

serve you.

We do not intentionally collect sensitive personal data (such as health information,

racial or ethnic origin, biometric data, etc.) as part of our service. Please refrain from

providing such data to us. Our service is not directed at children under 13, and we do

not knowingly collect personal data from children. If we learn that a child under 13 (or

under the applicable age of consent in their jurisdiction) has provided us personal

information, we will delete it.

3. How We Use Your Information: We use personal data for the following

purposes:

• Service Provision: To provide you with the purchased eSIM service,

including processing orders, delivering eSIM activation details, and enabling

connectivity with our network partners. For example, we use your device

identifiers to activate the eSIM profile, and use your data usage info to track

your plan balance.

• Account Management: To maintain and administer your account, including

verifying your identity when you log in, managing your subscriptions or plans,

and allowing you to view usage or purchase history.

• Customer Support: To assist you when you contact us with questions,

issues, or complaints. We use your info to troubleshoot, provide technical

support, or answer your inquiries.

• Payments and Fraud Prevention: To process payments (via our payment

processor) and to protect against fraudulent transactions. We may use your IP

or device info to help identify potentially fraudulent or abusive activity. Before

fulfilling an order, we might perform anti-fraud checks as permitted by law.

• Communication: To send you service-related communications (e.g.,

confirmations of your purchases, notices of plan expiration, updates on

network issues, or changes to our terms or policies). These are not marketing

messages but necessary notices. We may also send customer satisfaction

surveys or requests for feedback to improve our service.

• Marketing (with consent): If you have given consent (or as otherwise

permitted by law), we may send you promotional emails about new eSIM

plans, discounts, referral programs, or other news about Qonnect that might

interest you. You can opt out of marketing communications at any time by

using the unsubscribe link in emails or contacting us. We will not spam you,

and we typically send marketing communications only to those who have

agreed or to existing customers in line with applicable laws.

• Analytics and Improvement: To analyze how our service and website/app

are used, in order to improve our offerings and user experience. For instance,

we might look at aggregated usage patterns to determine which destinations

have high demand to negotiate better network deals, or analyze website trafficto improve design and navigation. For analytics, we may use third-party tools

like Google Analytics, which use cookies (with appropriate consent controls).

• Legal Compliance and Security: To comply with legal obligations, such as

keeping proper transaction records for tax and accounting, or responding to

lawful requests by public authorities (e.g., law enforcement requests). We

may also process data as reasonably necessary to establish or defend legal

claims, to enforce our terms (e.g., investigating misuse or network abuse), or

to protect our rights, property, or safety of Qonnect, our users, or others.

• Transfers and Updates: If we ever plan to transfer your data as part of a

business transfer (see Section 6 below on sharing, e.g., if our company is

acquired), or if we need to notify you of important service updates, we will use

your contact information for those purposes as well.

We will only use your personal data for the purposes above and will ensure we have

a valid legal basis for each use. For users in the EU/UK, our legal bases include:

performing a contract (providing the service you asked for), compliance with legal

obligations, your consent (for optional uses like marketing or certain cookies), and

our legitimate interests (such as improving our services or preventing fraud),

balanced against your rights.

4. Cookies and Tracking Technologies: Please refer to our detailed Cookie Policy

in the next section for information on how we use cookies, what types of cookies we

set, and how you can manage your preferences. In summary, we use cookies to

remember your preferences, keep you logged in, analyze traffic, and for limited

advertising or referral tracking purposes. We obtain consent for non-essential

cookies as required by law.

5. How We Share Your Information: We value your privacy and share personal

data only as necessary. The situations in which we share information include:

• Service Providers: We use trusted third-party companies to perform certain

business-related functions on our behalf. Examples include payment

processing (e.g., Stripe), cloud hosting and storage (for our website, app, and

data, possibly on providers like Amazon Web Services or Google Cloud),

email delivery services (for sending confirmations or newsletters), analytics

services, customer support software, and telecommunications partners (to

enable the eSIM connectivity). These service providers only receive the

information needed to perform their specific services, and we contractually

require them to protect your data and use it only for our purposes and in

compliance with law.

• Telecom Network Partners: In order to provide global connectivity, Qonnect

partners with mobile network operators and eSIM platform providers. For your

eSIM to work in a given country, the local network operator may need certain

information such as the eSIM identifier, your device's identifiers, and the

profile to download. We share the minimum necessary data with these

partners to activate and operate your service. These partners act as

independent data controllers for the connectivity they provide, and they are

subject to their own regulatory obligations (for example, some jurisdictions

require telecom providers to retain connection logs for a certain period).• Business Transfers: If Neovation Technologies LLC (Qonnect) is involved in

a merger, acquisition, financing due diligence, reorganization, bankruptcy,

receivership, sale of company assets, or transition of service to another

provider, your information may be transferred as part of such a transaction. In

such cases, we will ensure the new owner will similarly honor the protections

of this Privacy Policy or inform you if changes to the policy will be made.

• Legal Compliance and Protection: We may disclose personal information if

required to do so by law or in response to valid legal requests (e.g., a

subpoena, court order, or government demand in a jurisdiction we deem

appropriate). We may also share information when we believe in good faith

that disclosure is necessary to protect our rights or property, to investigate

fraud or a breach of our terms, to enforce our agreements, or to protect the

safety of our users or others.

• Affiliates: We may share information with our corporate affiliates (e.g., if we

have subsidiary or parent companies) for purposes consistent with this policy.

Currently, if Neovation Technologies LLC has no affiliates outside itself, this

may not apply, but if that changes we'll update the policy.

• With Consent: Other than the cases above, if we want to share your

information for other purposes, we will ask for your consent. For example, if

we ever wanted to feature a customer’s story or share data with a partner for

their own marketing, we would only do so if you agreed.

Importantly, we do not sell your personal data to third parties for monetary

consideration. We also do not share personal data with third parties for their own

direct marketing use unless you have given consent. If in the future Qonnect were to

be involved in any arrangement that might be considered a "sale" of personal

information under certain laws like the CCPA (California Consumer Privacy Act) – for

instance, sharing data for targeted advertising – we will provide proper notice and

ability to opt-out as required.

6. International Data Transfers: Qonnect is based in the United States, and many

of our systems and providers are located in the U.S. If you are using our service from

outside the U.S., your personal information will likely be transferred to and processed

in the United States and possibly other countries that may not have the same data

protection laws as your home jurisdiction. However, we will take steps to ensure that

adequate safeguards are in place to protect your data in accordance with this

• If you are in the European Economic Area (EEA), United Kingdom, or

Switzerland, we rely on lawful transfer mechanisms such as the European

Commission’s Standard Contractual Clauses (SCCs) or other approved

measures to ensure your data is protected when transferred to the U.S. or

other countries outside the EEA. We also limit the transfer of data to only what

is necessary for the purposes outlined.

• We may also rely on the necessity of the transfer to perform a contract with

you (for example, to deliver the service you asked for we have to route data

internationally).

• By using Qonnect, you understand that your data will be transferred to the

U.S. and other jurisdictions as needed for service provision, and you consent

to such transfer where required.If you have questions about international transfers or want a copy of the relevant

safeguards in place, you can contact us at support@qonnect.com.

7. Data Retention: We keep personal data for as long as necessary to fulfill the

purposes for which it was collected, including any legal, accounting, or reporting

requirements. For example:

• Account information is kept as long as you have an active account. If you

delete your account or it’s inactive for a long period, we will purge or

anonymize data in accordance with our data retention policies (except to the

extent we need to keep it for legal reasons).

• Transaction records (purchases, invoices) are kept for a minimum period as

required for tax and financial regulations (for example, in the U.S. and many

jurisdictions, that might be 7 years).

• Support communications may be retained for a period to help us reference

past issues if you contact us again, and for training purposes.

• eSIM usage logs might be kept for a certain time to comply with telecom

regulations or to defend possible legal claims (e.g., records of data usage, IP

addresses used, etc., could be kept for a certain number of months as

mandated or permitted by law).

• If you subscribed to marketing communications, we keep your contact info on

that list until you unsubscribe or request deletion.

• We periodically review the data we have and delete or anonymize information

that is no longer needed.

When we delete personal data, we ensure it is removed from our active systems.

However, note that backup or archival copies might persist for a period (we have

procedures to eventually delete or overwrite those too). Also, we may retain an

anonymized version of your data (stripped of personal identifiers) for statistical or

analytical purposes.

8. Your Rights and Choices: Depending on your jurisdiction, you have certain

rights regarding your personal data. We are committed to honoring those rights.

These may include:

• Access: You have the right to request a copy of the personal data we hold

about you, and to obtain information about how we process it.

• Rectification: You can ask us to correct any inaccurate or incomplete

personal information. (Much of your basic account info can be updated by you

directly in your account settings as well.)

• Erasure: You can request that we delete your personal data. We will do so,

provided we do not have a legal obligation or overriding legitimate interest to

retain it. Please note that if you request deletion of your data, this may result

in closure of your account and termination of services (since we need certain

data to provide the service).

• Restriction: You have the right to ask us to restrict processing of your data in

certain circumstances (for example, if you contest the accuracy of data, we

may limit processing while verifying).

• Objection: You may object to our processing of your data where we rely on

legitimate interests, and we will consider your request. You also have anunconditional right to object to processing of your data for direct marketing

purposes at any time.

• Data Portability: For data you provided to us and which we process by

automated means on the basis of consent or contract, you can request to

receive it in a structured, commonly used, machine-readable format, or ask

that we transfer it to another provider where technically feasible.

• Withdraw Consent: If we are processing your personal data based on your

consent (such as for marketing or certain types of cookies), you have the right

to withdraw that consent at any time. Withdrawal of consent will not affect the

lawfulness of processing done before the withdrawal.

• California Privacy Rights (CCPA/CPRA): If you are a California resident, in

addition to the above rights (to access, deletion, etc.), you have the right to

request information about the categories of personal information we have

collected and disclosed for business purposes in the last 12 months, the

categories of sources of that information, the business or commercial purpose

for collection, and the categories of third parties with whom we shared

personal information. You also have the right to opt out of any “sale” of your

personal information. As noted, we do not sell personal data for monetary

value, and we do not share data in a way that constitutes a sale under CCPA.

If that ever changes, we will implement a “Do Not Sell or Share My Personal

Information” link or similar mechanism. California users also have the right to

not receive discriminatory treatment for exercising their privacy rights.

• Marketing Communications: Regardless of jurisdiction, you can always opt

out of email marketing by clicking the unsubscribe link in any marketing email,

or by contacting our support. (Transactional or service emails will still be sent

as needed for service issues or billing.)

To exercise any of your rights, please contact us at support@qonnect.com with your

request. We may need to verify your identity before fulfilling certain requests (to

ensure that it’s you making the request and not an unauthorized person). For

example, we might ask you to confirm some identifying information or reply from the

email associated with your account. For requests to access or delete, in some cases

we may need to ask for additional proof if the info provided is not sufficient to verify.

For California residents: If you want to designate an authorized agent to make a

request on your behalf, we will require proof of the agent’s authority and verification

of your identity directly from you, unless the agent has an appropriate power of

attorney.

We will respond to your request within the timeframe required by law (e.g., generally

within 30 days for GDPR requests, and 45 days for CCPA requests, with possible

extension). There is no fee for making a request, though if requests become

manifestly unfounded or excessive we reserve rights allowed by law (such as

charging a fee or refusing repetitive requests).

If you have concerns about our data practices, we encourage you to contact us first

so we can try to resolve it. However, if you are in the EU/UK and believe we have not

addressed your concerns, you have the right to lodge a complaint with your local

data protection supervisory authority. For example, in the UK it’s the InformationCommissioner’s Office (ICO); in the EU, you can contact the authority in your country

of residence.

9. Security: We employ technical and organizational measures designed to protect

your personal information from unauthorized access, loss, misuse, or alteration. This

includes encryption of sensitive data in transit (e.g., our site uses HTTPS, and we

encourage use of secure methods for eSIM profile delivery), encryption of data at

rest where appropriate, firewalls and access controls on our servers, and limiting

access to personal data to employees and contractors who need it to operate our

service (and who are subject to confidentiality obligations). We also continually

review and update our security practices to guard against new threats.

However, no internet or email transmission is ever completely secure or error-free.

We cannot guarantee absolute security of data. You should take steps as well to

protect your information – for example, use a strong, unique password for your

Qonnect account, do not share your activation codes or QR eSIM with untrusted

parties, and alert us if you suspect any unauthorized activity. In the unlikely event of

a data breach that affects your personal information, we will notify you and

appropriate authorities as required by law.

10. Third-Party Services and Integrations: As mentioned, we use certain third-

party services in our operations which may collect data independently (e.g., Google

Analytics might set cookies, or the app store might collect info when you download

our app). Our website may also include social media widgets or login integrations

(for example, "Sign in with Google" or similar), which collect data under the privacy

policies of those providers. Any information you provide to third parties through those

interactions is governed by their policies, not this one. We encourage you to review

the privacy notices of any third-party services you interact with.

11. Cookie Policy Reference: For details on cookies and online tracking, please

see the Cookie Policy section below, which is an integral part of our privacy

practices.

12. Changes to this Privacy Policy: We may update this Privacy Policy from time

to time as our services and legal obligations evolve. If we make significant changes,

we will notify users through the website or via email (for major changes) and update

the “Last Updated” date at the top of this document. We encourage you to review

this Privacy Policy periodically for any updates. Continued use of Qonnect after any

changes signifies your acceptance of the revised policy.

13. Contact Us: If you have any questions, concerns, or requests regarding this

• Email: support@qonnect.com

• Mail: Neovation Technologies LLC – Privacy, 8206 Louisiana Blvd NE, Ste A,

Albuquerque, NM 87113, USA.

We will be happy to assist you.

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