Last updated: August 26, 2026

New POS Network (HK) Limited (“Kigo”, “we”, “us”, “our”), located at Rm 01‑06, 24/F, Sino Favour Centre, 1 On Yip Street, Chai Wan, Hong Kong, is the data controller for all personal data collected through our website, mobile application, and eSIM services (collectively the “Services”).

This Privacy Policy explains how we collect, use, store, transfer, and protect your personal data, as well as your statutory privacy rights. This policy does not apply to third‑party websites, applications, or services that we do not own or control. We are not responsible for third‑party privacy practices. Please review third‑party policies before use.

1. Information We Collect

1.1 Personal Identifiable Information

We collect personal data you voluntarily provide when registering an account, purchasing eSIM plans, contacting support, or submitting forms, including your name, email address, phone number, and payment-related details. We also collect service-specific operational data necessary to deliver eSIM services, such as ICCID, purchased plan records, and service usage logs. ICCID is mandatory for eSIM activation and cannot be omitted.

1.2 Sensitive Personal Data

We do not intentionally collect or store sensitive personal data, including identification numbers, political or religious beliefs, health data, biometrics, genetic information, criminal records, or union memberships. Please refrain from submitting sensitive data through our Services. If you voluntarily provide sensitive data, you consent to limited processing solely to resolve your request, and we will not store such information long-term.

1.3 Non-Personal & Automatically Collected Data

We automatically collect non-identifiable usage data, including IP address, device type, browser information, system language, general geolocation, visit time, page interactions, and log data. This information is used to maintain service stability, analyze usage trends, troubleshoot errors, and improve user experience.

1.4 Cookies and Tracking Technologies

We use essential and functional cookies to keep our website and application running. We also use analytical cookies to collect anonymous user behavior data. You may control or disable cookies through your browser settings. Disabling cookies may affect certain service functions.

2. How We Use Your Data

We process your personal data only based on contract performance, legitimate business interests, legal compliance, or your explicit consent:

• Operate, maintain, and optimize eSIM network services
• Manage user accounts, process orders, payments, and after-sales support
• Send technical notices, service updates, security alerts, and administrative messages
• Prevent fraud, monitor risk, and protect platform and user security
• Administer promotions, referral programs, and user activities
• Send marketing content only with your explicit opt-in consent. You may withdraw consent at any time
• Comply with Hong Kong and international legal and regulatory requirements

We may share limited necessary data with trusted third-party service providers (payment processors, cloud providers, support vendors) under strict confidentiality agreements. Third parties may only use your data to perform authorized services and cannot reuse it for other purposes.

3. Data Retention

We retain personal data only as long as necessary to fulfill service purposes:

• Service and usage data: retained during service validity and deleted after service termination unless legally required
• Transaction, billing, and payment records: retained for 7 years to comply with Hong Kong commercial and tax regulations
• Support records: retained for 3 years for dispute resolution and service improvement

When data is no longer required, we securely delete or anonymize it.

4. Data Disclosure & Transfers

We will not disclose your personal data except in the following circumstances:

• You provide explicit consent for disclosure
• Required by law, court orders, subpoenas, or government regulatory requests
• Necessary to prevent fraud, illegal activity, or security threats
• Necessary to complete your requested eSIM services
• In connection with company merger, asset sale, or business restructuring with confidentiality safeguards

Our Services are global. Your data may be stored or processed outside Hong Kong. We use Standard Contractual Clauses (SCCs) and other approved safeguards to ensure cross-border data protection compliance with GDPR and international privacy standards. Aggregated anonymous data may be shared for business analytics.

5. User Privacy Rights

You may exercise the following rights by contacting us at service@kigoesim.com. We will respond to valid requests within 30 days:

• Access and obtain a copy of your stored personal data
• Correct inaccurate or outdated information
• Request deletion of your data where no legal processing ground exists
• Restrict data processing and request data portability
• Opt out of all marketing communications
• Withdraw any previously granted consent

Users in the EU, UK, Switzerland, and other regions may file complaints with local data protection authorities. Hong Kong users may contact the Office of the Privacy Commissioner for Personal Data.

6. Regional Privacy Provisions

California Users (CCPA): We do not sell your personal data. You have the right to access, delete, and opt out of data sharing for targeted advertising.

Global Users: We apply consistent GDPR-aligned privacy standards for all users worldwide, regardless of jurisdiction.

7. Data Breach Notification

In the event of a data security breach, we will promptly contain and investigate the incident. We will notify affected users and relevant regulatory authorities within legally required timeframes if the breach poses a risk to user privacy and data security.

8. Children’s Privacy

Our Services are intended for users aged 13 and above. We do not knowingly collect personal data from children under 13. If we discover minor user data, we will delete it immediately.

9. Security Protection

We adopt industry-standard security measures, including SSL encryption for data in transit, firewall protection, role-based access control, and secure encrypted servers. While we strive to protect your data, no electronic storage or transmission method is 100% secure. You are responsible for safeguarding your account password. Please contact us immediately if you suspect account security risks.

10. Policy Updates

We may update this Privacy Policy from time to time. Material changes will be notified via website notice or email. The updated policy takes effect upon publication. Your continued use of the Services constitutes acceptance of the revised policy.

11. Contact Us

For privacy inquiries, data requests, or concerns, please contact us at: service@kigoesim.com