Privacy Policy

Website: esim.bar
Effective Date: 29.10.2025

1. Who we are

CashCom Systems Limited acts as a "data user" under the Personal Data (Privacy) Ordinance (PDPO) regarding personal data processed through the website and in connection with orders.

2. Categories of data

  • Contact: e-mail, name (if provided), language/region;
  • Order data: plan, amount, currency, payment status (masked payment data via provider);
  • Technical data: IP address, device/OS/browser type, timestamps, general geolocation by IP, eSIM installation logs;
  • Support: inquiries, attachments (screenshots, etc.);
  • Marketing preferences: consents/opt-outs.

3. Purposes of use (Schedule 1 PDPO - DPP1/DPP3)

  • Contract execution and electronic delivery of eSIM;
  • Customer support and problem diagnosis;
  • Security and fraud prevention;
  • Accounting and legal compliance;
  • Direct marketing only with your separate consent (see section 8).

4. Legal grounds and notification

We process data to the extent necessary for the purposes notified in this Policy and interface (cookie banner/forms). Providing an e-mail is necessary for purchasing without registration.

5. Cookies and identifiers

We use cookies/SDK/pixels for website operation, analytics, and (with your consent) marketing. Details are in /legal/cookies. Settings are available in the banner and browser.

6. Data transfer to third parties

We engage processors (payment gateways, e-mail/hosting/analytics, anti-fraud). Data may be transferred outside Hong Kong. We apply contractual measures to ensure a comparable level of protection and minimize the volume of transferred data.

7. Retention periods

  • Transactions/accounting - at least 7 years;
  • Support inquiries - 2 years;
  • Marketing preferences - until consent is withdrawn;
  • Technical logs - as needed and within reasonable timeframes.

8. Direct marketing (opt-in)

We use your e-mail for newsletters only after explicit consent (checkbox) and provide an easy way to unsubscribe (link "Unsubscribe"/request to mp@cashcom.org). Refusal does not affect contract execution.

9. Your rights

You have the right to request access/copy of your data, its correction, and information on its use. Send requests to [mp@cashcom.org]. We will respond within a reasonable time; a legally permitted fee may be charged for access if significant processing costs are incurred.

10. Security

We implement technical and organizational security measures: encryption, access control, audit logs, data minimization, contractual obligations of processors, staff training.

11. Children

The website is not intended for individuals under 16 years old. We do not knowingly collect their data.

12. Security incidents

In the event of a significant security incident, we will notify affected individuals without undue delay and, if necessary, the regulator.

13. Changes

We may update the Policy. The current version is published at /legal/privacy; in case of significant changes, notification via e-mail (if applicable).

14. Contacts

Contact for privacy/DPO: mp@cashcom.org.
Company: CashCom Systems Limited, reg. no. 75966875, address: Rm 301 Unit C, 2/F, Kwong On Bank Mongkok Branch Bldg 728-730, Nathan Rd Kln, Hong Kong.