Effective Date: 22 September 2025
Operator: Exenialum Ltd
Company number SC788748
Registered address: 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN

Introduction

This Privacy Policy explains how Exenialum Ltd (“Exenialum”, “we”, “our”, “us”) collects, processes, uses, stores, and protects the personal data of Account Holders (“you”, “your”) when you create an Account, Top-Up Balance, purchase Plans, or otherwise use Exenialum Products and Services.

By registering for an Account or using Exenialum Services, you agree to this Privacy Policy. If you do not agree, you should not register or use Exenialum Products or Services.

Information We Collect

When you register, Top-Up, or use Services, we may collect the following categories of information:

• Account Registration Data: first name, last name, valid email address, and password.
• Payment Data: payment method details (e.g., partial card information for VISA/Mastercard transactions), transaction references, Top-Up amounts, and currency.
• Service Data: purchase history, Balance records, Plan activations, usage records, and device compatibility information.
• Technical Data: IP address, device identifiers, operating system, browser type, network operator, and geolocation data necessary to provide Services.
• Support Data: communications with Exenialum (including emails, support requests, or refund inquiries).

Sharing of Information

• Service Providers: We may share your personal data with trusted third-party service providers (such as payment processors, hosting partners, and network operators) strictly for the purpose of providing Exenialum Services.
• Legal Obligations: We may disclose your data when required by applicable law, regulation, legal process, or government request.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring, your data may be transferred to the successor entity.

We do not sell or rent your personal data to third parties.

Data Retention

• Account data is retained as long as your Account remains active.
• If your Account is inactive for more than 18 months, Exenialum reserves the right to delete it and associated data.
• Payment and transaction records may be retained as required by applicable financial and tax regulations.
• You may request the deletion of your Account and data at any time by contacting Exenialum directly.

Data Security

• We implement appropriate technical and organizational measures to protect your personal data against loss, misuse, unauthorized access, disclosure, alteration, or destruction.
• However, no digital transmission or storage system is completely secure. By using the Services, you acknowledge that absolute security cannot be guaranteed.

International Data Transfers

• Exenialum may process or store data in countries outside your own jurisdiction when working with international service providers or network operators.
• Where such transfers occur, Exenialum ensures adequate safeguards consistent with applicable data protection laws.

Your Rights

If you are a resident of the United Kingdom, your personal data is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Under these laws, you have the following rights:

• Right of Access – to request confirmation of whether we process your personal data and to receive a copy of that data.
• Right to Rectification – to request correction of inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”) – to request deletion of your data where there is no lawful basis for retention.
• Right to Restrict Processing – to request suspension or limitation of processing in certain circumstances.
• Right to Data Portability – to request that your data be provided in a structured, commonly used, machine-readable format and, where technically feasible, transmitted to another controller.
• Right to Object – to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent – to withdraw previously given consent at any time without affecting the lawfulness of prior processing.
• Rights in Relation to Automated Decision-Making – to not be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects, unless permitted by law.

If you are a resident outside the United Kingdom, your personal data will be processed in accordance with the data protection legislation applicable in your country of residence, and you may enjoy rights equivalent to, or in some cases broader than, those listed above. Exenialum will honour such rights where legally required.

To exercise your rights, you may contact us at info@esimexe.com .

If you reside in the UK, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO): https://ico.org.uk. If you reside elsewhere, you may lodge a complaint with your local data protection authority.

Changes to This Policy

• Exenialum may update this Privacy Policy from time to time.
• Updates will be published and take effect upon posting.
• Continued use of the Services after updates constitutes acceptance of the revised Privacy Policy.

Contact Information

For privacy-related inquiries or to exercise your rights, please contact:

Exenialum Ltd
Company number: SC788748
Registered address: 5 South Charlotte Street, Edinburgh, Scotland, EH2 4AN
Email: info@esimexe.com