Privacy Policy
1. Applicability of this Privacy Policy
This Privacy Policy applies to users of MEMORIES’s services globally, including users of MEMORIES’s applications, Partner Platform, websites, features, or other services, interactions (online and offline) with MEMORIES, employees, and job applicants (the “Services”).
This Privacy Policy describes how MEMORIES collects and uses data and applies to all Airalo users globally, unless they use a service covered by a separate privacy notice. This Privacy Policy specifically applies to:
End Users: Individuals who use and interact directly with Services via their MEMORIES account for their personal use.
Business Users: MEMORIES provides services to entities (“Business Users”) who directly and indirectly provide us with End Customer’s personal information in connection with those Business Users’ own business and activities.
End Customers: Individuals who receive services ordered by other MEMORIES account owners, for example, when you do business with, or otherwise transact with a Business User.
2. How we collect, disclose, and use personal information
We collect information about you in a variety of ways depending on how you interact with us and our Services, including:
Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, place an order, make a purchase, or contact us by phone, email, or otherwise.
Automatically, using cookies, server logs, and other similar technologies when you interact with us through our Services and/or through emails, where permitted by law or where you consent.
From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
Airalo classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality in order to ensure that information is given the appropriate level of protection. The “data controller” is the entity which determines the purposes and means of the data processing taking place. The “data processor” is an entity acting on behalf, and under the instructions, of a controller in processing personal information.
3. Information we collect
The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
Account Registration | We collect your name and contact information, including email, when you create an account. We also collect information relating to the actions that you perform while logged into your account. | We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. We may also process this information to fulfill our contract with you. |
Biometric information | Biometric identifiers from photo IDs and selfies. | We process biometric information with your explicit consent in order to confirm your identity through the eKYC process where required by law. |
Business Users | We collect the name, and contact information, including email, phone number, and physical address, of employees of our Business Users with whom we may interact. | We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing. |
Necessary Online Tracking Technologies | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. Clear GIFs refer to pixels that are loaded by your browser when you access a website. These tracking technologies may collect information about your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in making our website operate efficiently. |
Non-Essential Tracking Technologies | We may place tracking technologies on our website (e.g., cookies or pixels) that collect analytics, record how you interact with our website, or allow us to participate in behavior-based advertising. These technologies may collect information about your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We or a third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites. | Where required by law, we base the use of third-party cookies upon consent. |
Demographic Information | We collect personal information, such as your age or location. | We have a legitimate interest in understanding our users and providing tailored services. |
Job Applicants | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee, including your contact information, education, and job history. | We have a legitimate interest in evaluating individuals for a potential position in our workforce. In some contexts, we are also required by law to collect information about employees or applicants. We also have a legitimate interest in using your information to have efficient staffing and workforce operations. |