Last Updated: 07 July 2025

This Privacy Policy (“Policy”) describes how KEYWEALTH PARTNERS LTD (Company number: 15527653, “Company,” “we,” “us,” or “our”) processes and protects the personal data of users when they visit the website https://swansim.net (“Website”) and use our eSIM services (“Services”).

By accessing or using our Website and Services, you acknowledge that you have read and accepted the terms of this Policy. If you do not agree, please refrain from using the Website or Services.
You are solely responsible for your use of the Website and Services, as well as the accuracy and legality of the personal data you provide.

1. Information We Collect

We collect data either directly from you or automatically through your use of the Website and Services.

1.1 Data You Voluntarily Provide

• Account Information: Such as your name, contact details, and any data you submit during sign-up.
• Payment Details: Processed securely by PCI DSS-compliant third-party processors. We do not store card information.
• Support Communication: Messages or attachments sent to our customer support.
• Marketing Preferences: Your choices regarding promotional messages.

1.2 Automatically Collected Data

• Device Details: Browser, IP address, device ID, and operating system.
• Usage Metrics: Pages viewed, click patterns, and transaction history.
• Cookies & Trackers: See our Cookie Policy for more information.

2. How We Use Your Data

We use your personal data to deliver, manage, and improve our Services. This includes:

• Fulfilling and supporting your transactions
• Ensuring platform security and detecting misuse
• Communicating service updates or promotions (with your permission)
• Meeting our obligations under UK law
• Personalizing your experience based on preferences

Note: eSIM activation triggers immediate digital content delivery. By activating, you waive the 14-day cancellation right under the Consumer Contracts Regulations 2013.

3. Legal Basis (UK GDPR)

Our processing of personal data is based on the following legal grounds:

• Consent – if you provide clear permission for specific processing
• Contract – to provide services you have requested
• Legal Duty – to comply with applicable legal requirements
• Legitimate Interests – such as ensuring website security and improving services

4. Sharing of Information

We may share your personal data only when necessary, with:

• Trusted vendors (e.g. payment processors, analytics, or anti-fraud providers)
• Government or regulatory bodies when mandated by law
• Third parties during a business restructure or acquisition
• eSIM network providers as needed to enable Services

We do not engage in the sale or leasing of your personal data.

5. Your Rights (UK & Global)

Subject to applicable laws, you may:

• Request access to or correction of your personal data
• Ask us to restrict or stop processing your data
• Obtain a copy of your data in portable format
• Withdraw consent for optional data uses

To exercise your rights, email us at [email protected]

6. Data Storage and Security

We implement security practices to protect your data. While no system is immune to breaches, we take reasonable steps to mitigate risk.

Data Retention:

• Account records are kept while your account remains active
• Payment and transaction data is retained as required by UK tax law
• You may request deletion where legally permissible

7. International Data Transfers

Where we transfer your data internationally, we rely on legal safeguards such as the UK’s IDTA or the UK Addendum to EU Standard Contractual Clauses, as authorized by the UK Information Commissioner’s Office.

8. Cookies and Trackers

We use various types of cookies to enhance user experience:

• Essential cookies – Required for login and core functionality
• Analytics cookies – To gather anonymized usage insights
• Advertising cookies – Enabled only with your permission

You can manage cookies in your browser. Disabling them may reduce functionality.

9. Liability Disclaimer

• Use at your discretion – we disclaim all liability to the extent permitted by law
• You are responsible for submitting accurate data
• Ensure your use of Services complies with your local regulations
• We are not liable for the privacy practices of third-party websites linked from ours

10. Policy Updates

This Policy may be updated occasionally. Substantial changes will be communicated via our Website or email.

11. Governing Law

This Policy is governed by the laws of England and Wales.

Any disputes will fall under the jurisdiction of the courts of England.

12. Contact Us

If you have questions or would like to exercise your rights, contact us at:

Email: [email protected]

Your continued use of the Website indicates acceptance of this Policy and any subsequent updates.