Privacy policy

1. Introduction

Unception, registered under number 948 267 638, operates and markets under the Sabily brand telecommunications services via SIM and eSIM cards. We attach the utmost importance to the protection of your personal data.

This privacy policy is intended to inform you how we collect, use, store and protect your personal information when you use our services, in accordance with the General Data Protection Regulation (GDPR) and applicable French law.

2.1 Personal data

When interacting with our services, we may collect the following personal data:

• Identification details: surname, first name, date of birth.
• Contact details: postal address, email address, telephone number.
• Payment information: bank details or other information required to process transactions.
• Technical data: IP address, device type, operating system, unique device identifiers.
• Location data: information about your geographical position when you use our services.

2.2 Non-personal data

We may also collect anonymous or aggregated data, such as usage statistics, which do not allow you to be directly identified.

3. Use of data

Your personal data may be used to:

• Provide the service: activate and manage your SIM/eSIM card, ensure connectivity and customer support.
• Billing and payments: process your transactions and manage your customer account.
• Improve the service: analyse the use of our services in order to optimise them and develop new features.
• Communicate: inform you of updates, special offers or other information relating to our services, subject to your prior consent where required.
• Comply with the law: meet our legal and regulatory obligations, particularly regarding data retention and cooperation with the competent authorities.

4. Data sharing

We undertake not to sell, rent or disclose your personal data to third parties without your consent, except in the following cases:

• Third-party service providers: partners or subcontractors who assist us in providing our services (for example, payment services, customer support). These third parties are required to respect the confidentiality of your data and to use it only in connection with the services they provide on our behalf.
• Legal obligations: where the law requires us to disclose your data, or in response to lawful requests from public authorities.

5. International data transfers

Your personal data is processed primarily within the European Union. However, some of our partners may be located in countries outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place, such as the use of standard contractual clauses approved by the European Commission, to guarantee an adequate level of protection for your data.

6. Data security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, alteration or disclosure. These measures include, among others, data encryption, firewalls and strict access controls.

7. Data retention period

We retain your personal data for as long as necessary for the purposes for which it was collected, or to comply with legal requirements. For example:

• Account data: retained for as long as your account is active and for a reasonable period after its deactivation.
• Transaction data: retained in accordance with applicable tax and accounting obligations.

8. Your rights

In accordance with applicable regulations, you have the following rights regarding your personal data:

• Right of access: obtain confirmation that data concerning you is being processed and receive a copy of it.
• Right to rectification: request the correction of inaccurate or incomplete data.
• Right to erasure: request the deletion of your data in certain circumstances.
• Right to restriction of processing: request the temporary suspension of the processing of your data.
• Right to object: object to the processing of your data on legitimate grounds or for direct marketing purposes.
• Right to portability: receive your data in a structured, commonly used format, or request its transfer to another controller.

9. Data of minors

Our services are not intended for persons under 18 without parental consent. If we learn that we have collected personal data from a minor without such authorisation, we will take the necessary steps to delete that information as soon as possible.

10. Contact

For any question concerning this privacy policy, or to exercise your rights, you may contact us:

• By email: contact@sabily.fr
• By post: Unception, 59 rue de Ponthieu, bureau 326, 75008 Paris, France

11. Changes to the privacy policy

We may amend this privacy policy to reflect legal, technological or operational developments. Any change will be published on our website and, where necessary, you will be informed by other means.