Privacy Policy

Introduction

tiino Limited ("tiino", "we", "us", or "our") is committed to protecting the privacy of every person who enquires about, accesses, or uses our private mobile network services. This Privacy Policy explains how we collect, use, store, and protect your personal information, and the rights you hold in respect of that information.

We operate a private eSIM and connectivity service available by introduction only. The nature of our service means we handle sensitive personal data with exceptional care and discretion.

Who We Are

tiino Limited is the data controller responsible for your personal information. For all privacy-related enquiries, please contact our Privacy team using the details at the bottom of this page.

Information We Collect

We may collect and process the following categories of personal information:

• Identity data: name, title, date of birth, nationality, and government-issued identification where required for regulatory compliance.
• Contact data: email address, telephone numbers, and postal address.
• Account and service data: eSIM provisioning records, device identifiers, network usage patterns, and service configuration preferences.
• Referral and introduction data: the identity of the person or entity who introduced you to tiino, where applicable.
• Financial data: billing information sufficient to process payments. We do not store full payment card details — all card processing is handled by our PCI-DSS compliant payment partners.
• Technical data: IP address, browser type and version, time zone, and device information collected when you access our website or services.
• Communications data: records of your correspondence with us, including service requests and support interactions.

We do not collect, record, or store the content of communications made over our network. tiino is designed so that no third party — including tiino itself — holds a position that would allow network communications to be intercepted.

How We Use Your Information

We use your personal information only where we have a lawful basis to do so. Our purposes include:

• Provisioning and managing your eSIM service and account.
• Verifying your identity and conducting due diligence as required by applicable law.
• Processing payments and maintaining financial records.
• Communicating with you about your service, including essential service notices.
• Improving and developing our services and website.
• Complying with legal obligations, regulatory requirements, and lawful requests from competent authorities.

We do not use your personal data for advertising purposes, and we do not sell or rent your information to any third party.

Legal Bases for Processing

We process your personal data under the following legal bases: (a) performance of a contract — to provide you with the services you have requested; (b) legal obligation — to comply with applicable laws and regulations; (c) legitimate interests — to operate, secure, and improve our business, where those interests are not overridden by your rights; and (d) consent — where you have given explicit consent, which you may withdraw at any time.

Data Sharing and Disclosure

We share your personal data only where necessary and only with:

• Telecommunications partners: our SIMSY infrastructure partners and roaming network providers, solely for the purpose of delivering connectivity services.
• Payment processors: compliant third-party payment providers processing transactions on our behalf.
• Professional advisors: lawyers, accountants, auditors, and insurers operating under binding confidentiality obligations.
• Regulatory authorities: where required by law, court order, or legitimate regulatory request.

We require all third parties to implement appropriate technical and organisational security measures and to process your data only on our documented instructions.

International Transfers

Because tiino operates as a global private network, your data may be processed in countries outside your jurisdiction. Where transfers occur outside the European Economic Area or the United Kingdom, we ensure appropriate safeguards are in place, including standard contractual clauses approved by competent data protection authorities.

Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law. Account data is held for the duration of your service relationship and for up to seven years thereafter for legal and financial record-keeping purposes. We will securely delete or anonymise your data when it is no longer required.

Security

We maintain robust technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include end-to-end encryption of sensitive data in transit and at rest, strict access controls, regular security assessments, and confidential handling procedures for all staff with access to personal information.

Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal data (subject to legal retention obligations).
• Object to or restrict certain types of processing.
• Receive a portable copy of your data in a structured, machine-readable format.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with a supervisory authority in your jurisdiction.

To exercise any of these rights, please contact us using the details below. We will respond within the timeframe required by applicable law.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Where material changes are made, we will notify you through your registered contact details or by posting a notice on our website. The date at the top of this page will always reflect the most recent revision.