Privacy Policy

SOZA Ventures LLC ("BreezySim," "we," "us," or "our") operates breezysim.com. We are committed to protecting your privacy. This Privacy Policy describes what personal information we collect, how we use and protect it, with whom we share it, and what rights you have regarding your data. Please read this policy carefully. By using our website or services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

Information You Provide Directly

• Identity and contact data: name, email address, and any information you provide when contacting our support team.
• Account credentials: username and password (stored in hashed form; we never store plaintext passwords).
• Payment data: billing address, and payment method details. Payment card information is collected and processed directly by our PCI-DSS-compliant payment processor; BreezySim does not store full card numbers or CVV codes.
• Device data: device model and, where required for eSIM provisioning, the Embedded SIM Identifier (EID) of your device.
• Communications: any messages, emails, or feedback you submit to us.

Information Collected Automatically

• Usage data: pages visited, time on site, referring URLs, and navigation patterns.
• Technical data: IP address, browser type and version, operating system, device type, and approximate geographic location derived from IP.
• Cookies and tracking data: see our Cookie Policy for full details.

Information from Third Parties

We may receive information from payment processors (transaction confirmation and fraud signals), network carriers (eSIM provisioning confirmation), and analytics providers (aggregated, anonymized usage metrics). We do not purchase marketing lists or acquire personal data from data brokers.

2. How We Use Your Information

We use your personal data only for the following purposes:

• Order processing and fulfillment: to process your purchase, provision your eSIM, and deliver activation instructions.
• Transactional communications: to send order confirmations, receipts, activation codes, and essential service notifications. These emails are sent as a necessary part of our service and cannot be opted out of.
• Marketing communications: to send promotional content, offers, and updates — but only where you have given your explicit consent. You may withdraw consent at any time.
• Customer support: to respond to your inquiries, troubleshoot issues, and improve support quality.
• Fraud prevention and security: to detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal activity.
• Service improvement: to analyze usage patterns and improve our website, products, and user experience.
• Legal compliance: to meet our obligations under applicable laws and regulations, including tax, financial reporting, and consumer protection requirements.

3. Legal Basis for Processing (EEA and UK Users)

For users located in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following legal bases:

Purpose	Legal Basis
Processing orders and delivering eSIMs	Performance of contract (Art. 6(1)(b) GDPR)
Sending transactional emails	Performance of contract (Art. 6(1)(b) GDPR)
Fraud detection and security	Legitimate interests (Art. 6(1)(f) GDPR)
Service improvement and analytics	Legitimate interests (Art. 6(1)(f) GDPR)
Marketing communications	Consent (Art. 6(1)(a) GDPR)
Non-essential cookies	Consent (Art. 6(1)(a) GDPR)
Tax records and legal compliance	Legal obligation (Art. 6(1)(c) GDPR)

4. Email Communications

Transactional emails — including order confirmations, eSIM activation codes, receipts, and service-critical notices — are sent automatically as part of the fulfillment of your purchase. These are not optional and cannot be unsubscribed from, as they are necessary to deliver the services you have purchased.

Marketing emails — including promotions, new product announcements, and updates — are sent only where you have explicitly opted in. You can withdraw your consent at any time by:

• clicking the "Unsubscribe" link in any marketing email; or
• emailing us at breeze@breezysim.com with a request to unsubscribe.

We comply with the CAN-SPAM Act (United States) and, where applicable, the GDPR requirements for email consent. We will process unsubscribe requests promptly, and in all cases within 10 business days.

5. Sharing Your Information

We do not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes — ever.

We share personal data only in these limited circumstances:

• Payment processors: We share necessary billing and transaction data with our payment processor to securely complete your purchase. They are contractually bound to handle your data in accordance with PCI-DSS standards and applicable privacy law.
• Network carriers and eSIM provisioning partners: We share limited device and plan data (such as EID and plan type) with the carrier network needed to activate your eSIM. This is the minimum data required to deliver the service.
• Analytics providers: We may share anonymized, aggregated usage data with analytics services to understand how our website is used. We configure these tools to minimize data collection where possible.
• Legal and regulatory authorities: We may disclose personal data where required by a valid court order, subpoena, regulatory demand, or where disclosure is necessary to protect the rights, property, or safety of BreezySim, our users, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections described here. We will notify you via email and/or a prominent website notice before your data is transferred and becomes subject to a different privacy policy.

6. International Data Transfers

BreezySim is a globally operating service. Your personal data may be transferred to, stored, and processed in the United States or other countries whose data protection laws may differ from those in your home country. When we transfer personal data from the EEA, UK, or Switzerland to countries not deemed adequate by the relevant authority, we rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to protect your data.

7. Data Retention

We retain your personal data for as long as necessary to:

• maintain your account and provide you with services;
• comply with legal and regulatory obligations (for example, financial and tax records are typically retained for 7 years);
• resolve disputes, enforce agreements, and protect against legal claims.

When data is no longer required for any of these purposes, we securely delete or irreversibly anonymize it. Anonymized data (which cannot identify you) may be retained indefinitely for statistical or analytical purposes.

8. Data Security

We implement and maintain industry-standard technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/HTTPS;
• Encryption of sensitive data at rest;
• Strict access controls limiting data access to personnel who need it to perform their duties;
• Regular security assessments and monitoring.

No method of electronic transmission or storage is 100% secure. While we take significant steps to protect your information, we cannot guarantee absolute security. In the event of a data breach that may affect your rights, we will notify you and the relevant authorities as required by applicable law.

9. Your Privacy Rights

California Residents — CCPA / CPRA

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, including the sources, purposes, and third parties with whom it has been shared.
• Right to Delete: You may request that we delete the personal information we have collected about you, subject to certain exceptions (e.g., information needed to complete a transaction or comply with a legal obligation).
• Right to Correct: You may request that we correct inaccurate personal information we hold about you.
• Right to Opt Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising. If this practice changes, we will update this policy and provide an opt-out mechanism.
• Right to Limit Sensitive Data Use: You may request that we limit the use and disclosure of sensitive personal information.
• Right to Non-Discrimination: We will not deny you services, charge you different prices, or provide a different quality of service because you exercised any of these rights.

To submit a CCPA request, contact us at breeze@breezysim.com with "Privacy Request" in the subject line. We will respond within 45 days. We may need to verify your identity before processing your request.

EEA and UK Residents — GDPR / UK GDPR

If you are located in the EEA or UK, you have the following rights under the General Data Protection Regulation (GDPR) or UK GDPR:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"): Request deletion of your personal data, subject to applicable exceptions.
• Right to restriction of processing: Request that we limit how we use your data in certain circumstances.
• Right to data portability: Receive your data in a structured, commonly used, machine-readable format.
• Right to object: Object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting the lawfulness of processing before withdrawal.
• Right to lodge a complaint: Lodge a complaint with your local supervisory authority if you believe we have not handled your data lawfully.

To exercise any of these rights, contact us at breeze@breezysim.com. We will respond within 30 days (extendable to 90 days for complex requests). We do not charge a fee for exercising your rights unless your requests are manifestly unfounded or excessive.

10. Children's Privacy

BreezySim services are intended for adults aged 18 and over. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take prompt steps to delete it. If you believe we may have collected information from a minor, please contact us at breeze@breezysim.com.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve our website. For a full description of the types of cookies we use, how to manage your preferences, and how to opt out, please see our Cookie Policy.

12. Links to Third-Party Sites

Our website may contain links to third-party websites for your convenience. We are not responsible for the privacy practices of any third-party site. We encourage you to review the privacy policies of any website you visit through links on breezysim.com.

13. 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 other factors. We will notify you of material changes by updating the "Effective" date above and, where required by law, by sending a notice to the email address associated with your account or by displaying a prominent notice on our website. We encourage you to review this policy periodically. Your continued use of our services after the effective date of any changes constitutes your acceptance of the revised policy.

14. Contact Us

For questions, concerns, or to exercise your privacy rights, please contact us at:

SOZA Ventures LLC (operating as BreezySim)
Email: breeze@breezysim.com
Website: breezysim.com

For EEA/UK users: if you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.