PRIVACY POLICY

Last Updated: June 17, 2026

This Privacy Policy ("Policy") explains how ROKKODE Inc. ("Company," "we," "us," or "our") collects, uses, discloses, retains, and protects information in connection with eSIMDB.

This Policy applies to the eSIMDB website, mobile applications, pages, search and comparison tools, review features, notifications, AI-powered features, chat interfaces, AI agents, external AI channels, affiliate links, promotions, contact forms, and any related services that link to this Policy or use eSIMDB data or functionality (collectively, the "Services").

By using the Services, you acknowledge that we process information as described in this Policy. If you do not agree with this Policy, please do not use the Services.

1. Who We Are

eSIMDB is an independent search, comparison, review, and referral platform for travel eSIM plans and eSIM service providers. The Services are operated by ROKKODE Inc.

For questions about this Policy or our handling of personal information, please contact us through the contact form available on the Services.

Our Terms of Use are available at: https://esimdb.com/terms

2. Information We Collect

We may collect the following categories of information, depending on how you use the Services.

2.1 Information You Provide

We collect information that you choose to provide directly to us, mainly when you submit a review, contact us, or use AI-powered features.

This may include:

• review content, ratings, display name, email address, and any other information you include in a review submission;
• your name, email address, inquiry details, and any other information you include when contacting us;
• prompts, questions, search conditions, travel preferences, and other information you submit to AI-powered features;
• information you provide when you report a problem, request correction or deletion, or exercise privacy rights.

Please do not submit sensitive personal information, eSIM QR codes, activation codes, account credentials, payment information, travel documents, or personal information about another person unless you have the legal right to do so.

2.2 Information Collected Automatically

When you use the Services, we and our service providers may automatically collect information such as:

• IP address, approximate location derived from IP address, browser type, browser version, device type, operating system, language settings, and device settings;
• pages viewed, searches performed, filters used, plans viewed, provider links clicked, promotional codes viewed or used, referring pages, exit pages, dates and times of visits, and time spent on pages;
• cookie identifiers, analytics identifiers, affiliate attribution identifiers, session identifiers, advertising identifiers where applicable, and similar online identifiers;
• mobile app diagnostics, crash logs, performance data, app version, device identifiers, and push notification tokens if applicable;
• AI feature usage data, such as prompts, questions, search conditions, destination queries, travel preferences, device requirements, conversation history, AI responses, errors, safety logs, and related usage events where applicable;
• security and anti-abuse signals, including request patterns, rate-limit events, suspicious traffic indicators, bot detection signals, spam detection signals, and scraping-related logs.

2.3 Information from Third Parties

We may receive information from third parties, including:

• analytics, affiliate, fraud prevention, security, hosting, app platform, and infrastructure providers;
• third-party AI providers, AI platform operators, external AI channels, or AI infrastructure providers where we use them to provide or support AI-powered features;
• eSIM providers, affiliate networks, and content partners;
• users who submit reviews, reports, corrections, or complaints;
• public sources and third-party sources used to maintain or improve eSIM plan listings.

3. How We Use Information

We may use information for the following purposes:

• provide, operate, maintain, and improve the Services;
• enable search, comparison, filtering, recommendations, reviews, contact forms, notifications, and related features;
• provide AI-powered features, generate responses, summarize or compare eSIM plans, answer questions, and route relevant eSIMDB data to AI features;
• display, moderate, analyze, verify, and manage reviews and other user-generated content;
• respond to inquiries, requests, complaints, and rights requests;
• personalize content, remember preferences, and improve user experience;
• measure traffic, usage, performance, conversions, affiliate attribution, and promotion performance;
• show, measure, and improve sponsored placements, promotional offers, and affiliate links, where applicable;
• detect, prevent, investigate, and respond to spam, fake reviews, scraping, bot activity, abusive traffic, security incidents, fraud, policy violations, and other harmful activity;
• review, monitor, evaluate, debug, and improve AI feature quality, safety, and reliability;
• debug, repair, secure, and protect the Services;
• comply with legal obligations, respond to lawful requests, enforce our Terms of Use, and protect our rights, users, providers, partners, and the public;
• carry out any other purpose disclosed to you at the time of collection or with your consent.

4. Legal Bases for EEA and UK Users

If you are located in the European Economic Area, the United Kingdom, or another region with similar legal basis requirements, we rely on one or more of the following legal bases.

Where we rely on legitimate interests, our interests may include operating and improving the Services, measuring service performance, protecting the Services from abuse, preventing spam and scraping, maintaining accurate listings and reviews, and supporting our business through affiliate and sponsored-placement relationships.

Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal.

5. Cookies, Analytics, and Affiliate Tracking

We and our service providers may use cookies, SDKs, pixels, local storage, mobile identifiers, and similar technologies to operate the Services and understand how they are used.

5.1 Types of Technologies We Use

• Essential technologies: used for core service functions, security, fraud prevention, load balancing, and remembering privacy choices.
• Analytics technologies: used to understand traffic, searches, clicks, page views, app performance, and feature usage.
• Functionality technologies: used to remember preferences such as language, region, filters, or display settings.
• Advertising or sponsored-content technologies: used to display, measure, limit, and improve advertisements or sponsored content, where applicable.
• Affiliate attribution technologies: used to measure clicks, referrals, promotional code usage, conversions, and commissions from provider or affiliate links.

5.2 Your Choices

You can usually control cookies through your browser settings. Mobile operating systems may provide controls for advertising identifiers, push notifications, app tracking, and analytics. If we use a cookie consent tool, you may use it to accept, reject, or change choices for non-essential cookies where required.

Blocking cookies or identifiers may affect the availability or performance of some Services.

Some browsers or extensions may send "Do Not Track" signals. Because there is no consistent industry standard for these signals, we may not respond to them unless required by law. Where required by applicable law, we will honor recognized opt-out preference signals, such as Global Privacy Control, for applicable processing.

6. Reviews and Public Content

If you submit a review, rating, comment, correction, report, photo, or other user-generated content, that content and associated display information may be published or displayed on the Services.

We may process review-related information, including review text, rating, provider or plan reviewed, display name, email address, submission time, IP address, device information, moderation history, and anti-abuse signals. We use this information to operate review features, detect fake reviews, prevent spam and manipulation, respond to complaints, enforce our Terms of Use, and improve the Services.

Do not include private information, sensitive information, eSIM QR codes, activation codes, payment details, travel documents, or another person's personal information in reviews or other public submissions.

7. AI Features and User Inputs

If you use AI-powered features, chat interfaces, AI agents, external AI channels, or similar tools connected to eSIMDB, we may process the information you submit and the related AI interaction data. This may include prompts, questions, search conditions, destination queries, travel dates or preferences, data needs, device requirements, conversation history, AI-generated responses, errors, safety logs, and usage events.

We may use this information to provide AI-powered eSIM search and comparison, generate responses, retrieve relevant eSIMDB data, improve feature quality and reliability, debug errors, detect abuse, prevent scraping or automated data extraction, enforce our Terms of Use, and protect the Services.

We may use third-party AI providers, AI infrastructure providers, or external AI channels to provide or support AI features. Where we do so, information you submit to AI features and related context may be processed by those providers or channels under their own terms and privacy policies, as applicable.

Do not submit private information, sensitive information, payment information, eSIM QR codes, activation codes, account credentials, identity documents, or another person's personal information to AI features unless you have the legal right to do so and the information is necessary for your request.

This Policy does not currently describe any use of AI inputs or conversation history to train AI models. If our practices materially change, including if we decide to use such data for model training in a way that requires additional notice or consent, we will update this Policy and take any other steps required by applicable law.

8. How We Share Information with Third Parties

We do not sell personal information for money. We may share information with the following categories of recipients where appropriate:

• Service providers and processors: vendors that process information on our behalf, such as hosting, cloud infrastructure, analytics, databases, monitoring, email/contact tools, customer support, app diagnostics, security, fraud prevention, and similar service providers.
• Affiliate and measurement partners: partners that help us measure clicks, referrals, promotional code usage, conversions, and commissions. We may share limited referral or attribution information with these partners where necessary for those purposes.
• AI providers and external AI channels: third-party AI providers, AI infrastructure providers, or external AI channels that help us provide, operate, secure, monitor, or improve AI-powered features, where applicable.
• Provider links and third-party services: we do not directly provide your email address, review content, inquiry details, or other contact details to eSIM providers merely because you click a provider link. When you leave eSIMDB and visit a provider website, app, payment page, support page, or other third-party service, that third party may collect information from you under its own privacy policy and terms.
• App stores and platform providers: such as Apple, Google, and mobile operating system providers, where necessary for mobile app distribution, analytics, notifications, crash reporting, or platform features.
• Legal, compliance, and safety recipients: courts, regulators, law enforcement, government authorities, advisors, or other parties where we believe disclosure is required or appropriate.
• Business transfer recipients: parties involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction.
• With your consent or direction: where you ask us to share information or consent to a specific disclosure.

Third-party websites, apps, providers, app stores, affiliate partners, and other third-party services may process your information under their own privacy policies. We are not responsible for their privacy practices.

9. International Data Transfers

We are based in Japan, and the Services may be used globally. Your information may be processed in Japan and in other countries where we, our service providers, or our partners operate.

Where required by applicable law, we use appropriate safeguards for international transfers, which may include adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum or equivalent safeguards, the EU-U.S. Data Privacy Framework where applicable, or other lawful transfer mechanisms.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Retention periods may vary depending on the type of information and context, including:

• inquiries and contact records: for as long as needed to respond, maintain business records, and resolve disputes;
• reviews and user-generated content: for as long as the content remains published or as needed for moderation, fraud prevention, legal, or service integrity purposes;
• analytics and cookie data: according to the settings of the relevant analytics or cookie tools;
• affiliate and sponsored-placement records: for as long as needed to measure referrals, resolve partner disputes, calculate commissions, and maintain accounting records;
• security and anti-abuse logs: for as long as needed to detect, prevent, investigate, and respond to spam, scraping, bot activity, fraud, attacks, and other abuse;
• AI inputs, conversation history, AI responses, and AI safety logs: for as long as needed to provide AI features, debug errors, monitor quality and safety, prevent abuse, enforce our Terms of Use, and comply with legal obligations;
• legal and compliance records: for as long as needed to comply with law, enforce agreements, or protect rights.

We may retain de-identified, aggregated, or anonymized information for longer periods where it no longer identifies you.

11. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing, including processing based on legitimate interests;
• request data portability;
• withdraw consent where processing is based on consent;
• opt out of certain marketing communications;
• lodge a complaint with a data protection authority.

To exercise rights, please contact us through the contact form available on the Services. We may need to verify your identity before responding. We may deny or limit a request where permitted by law, including where we cannot verify your identity, the request is excessive, or retention is required for legal, security, fraud prevention, or service integrity purposes.

12. For California Residents

This section applies to California residents where the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), applies to us.

California residents may have the right to:

• know the categories and specific pieces of personal information we collect, use, disclose, sell, or share;
• know the categories of sources, purposes, and recipients of personal information;
• request deletion of personal information;
• request correction of inaccurate personal information;
• opt out of the sale or sharing of personal information, including sharing for cross-context behavioral advertising where applicable;
• limit the use or disclosure of sensitive personal information where applicable;
• not be discriminated against for exercising CCPA rights.

We do not sell personal information for money. However, some analytics, affiliate, sponsored-placement, or similar online tracking activities may be considered a "sale," "sharing," or targeted advertising under certain U.S. state privacy laws. Where required, we will provide a method to opt out, such as a "Do Not Sell or Share My Personal Information" or "Your Privacy Choices" link, and we will honor applicable opt-out preference signals such as Global Privacy Control.

To submit a California privacy request, please contact us through the contact form available on the Services. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and identity verification.

13. Children's Privacy

The Services are not directed to children. We generally do not verify users' ages, and we do not intend to knowingly collect personal information from children under 13.

If you believe that a child under 13 has provided personal information to us, please contact us so that we can take appropriate action.

14. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. These measures may include access controls, monitoring, logging, encryption where appropriate, security reviews, abuse detection, and vendor controls.

No method of transmission or storage is completely secure. We cannot guarantee absolute security of information.

15. External Links and Third-Party Providers

The Services may include links to eSIM providers, app stores, payment pages, support pages, social media pages, maps, advertisements, sponsored content, and other third-party services.

When you leave the Services or interact with a third party, that third party may collect, use, and share information under its own privacy policy and terms. We encourage you to review third-party privacy policies before providing information or making a purchase.

16. Changes to This Policy

We may update this Policy from time to time. When we make changes, we will update the "Last Updated" date above. Changes are effective when posted unless a different effective date is stated.

If we make material changes, we may provide additional notice through the Services, by email, in-app notice, or other reasonable means where appropriate.

17. Contact Us

If you have questions, concerns, complaints, or requests about this Policy or our handling of personal information, please contact us through the contact form available on the Services.