Last update: 6th December 2023

The company Ody SAS (“Kolet”, “we”, “us”, “our”) operates Kolet mobile application (the “Kolet App”) allowing you to activate your eSIM and order local plans at an affordable price depending on your travel destination.

While you are accessing and using the Kolet App, you communicate your personal data to Kolet. Please read this privacy policy carefully as it explains how Kolet uses your personal data and how exercise your rights accordingly. This privacy policy completes the Terms & Conditions, as well as any documents or notices that may refer to this privacy policy.

Should you have any questions, you may directly contact Kolet by sending an email at [email protected]

As publisher of Kolet App, Kolet is the data controller of the personal data collected for the administrative, operational and commercial management of the Kolet App.

When you order a plan, the local telephone operator is the data controller of the personal data related to this plan.

The provision of certain types of personal data may be necessary or optional, depending on the services you wish to receive. Mandatory data will be marked as such at the moment of collection. If you refuse to provide mandatory data, Kolet may not be able to process your request (e.g., eSIM activation request, order request, customer service request).

Most of your personal data are directly provided by you on Kolet App. However, when you decide to request an eSIM through a third-party service provider’s platform (e.g., your airline company, hotel, airport, etc.), this third-party service provider will communicate some of your personal data to Kolet (e.g., your email address, travel destination (country code) and travel start date) in order to allow us to proceed your eSIM request.

You may also decide to order an eSIM and associated plans for third parties on Kolet App. In this case, you shall ensure that you communicate such data to Kolet in accordance with the applicable personal data protection regulations, in particular by informing the third parties about the processing of their personal data by Kolet.

Furthermore, Kolet App also automatically collects the following data through cookies and other tracker technologies:

Kolet processes your personal data for the following purposes only:

Your personal data may be transmitted to the following recipients when you access and use Kolet App and its services:

As far as possible, your personal data is processed within the European Union (EU)/European Economic Area (EEA).

However, your personal data can be transferred to third countries due to the global nature of the services provided on Kolet App, in particular when you order a local plan provided by a telephone operator located outside the EU/EEA. In addition, Kolet uses service providers that may also be located outside the EU/EEA.

In the event that the third country does not ensure a level of protection of personal data equivalent to the EU/EEA, Kolet ensures that the personal data transfer is covered by appropriate safeguards (e.g., standard contractual clauses, transfer impact assessments, etc.). A copy of such safeguards can be obtained by sending an email directly to Kolet at [email protected]

Kolet has implemented appropriate technical and organizational measures in order to protect your personal data, in particular against potential personal data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures guarantee a level of security adapted to the data and take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected.

If you have found a vulnerability or would like to report a security incident, you may send an email at [email protected]

As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.

In the absence of applicable exceptions:

Beyond these retention periods, Kolet will store your personal data in an archived database during:

Regarding the cookies and other tracker technologies used on Kolet App:

If you are based in the EU/EEA/UK, you have the following rights over your personal data:

It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in Section 3 of this policy, as follows:

Depending on your country of residence, you may have additional local rights with respect to our processing of your personal data. For example, if you are based in France you can define either general or specific guidelines regarding your personal data in the event of your death (e.g., their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

Under certain circumstances, Kolet may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.

If you have any questions or wish to exercise your rights, you may directly contact Kolet by sending an email at [email protected]

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

This policy is clearly dated and may be modified and updated by Kolet at any time, in particular in the event of changes related to the services available on Kolet App or the applicable law. Therefore, we recommend that you consult this policy each time you access Kolet App. If applicable, the updated policy will be communicated to you by any appropriate means.