Privacy Policy

1. Introduction

Lakehouse Technologies Limited, Hong Kong ("we", "us", or "our") operates the fennec.mobi website and the fennec.mobi mobile application (collectively, the "Service"). We are committed to protecting your privacy and providing transparent information about how we handle your data. If you have any questions or concerns about this privacy notice or how we handle your personal information, please reach out to our support team via the Help Center in your profile. When you visit our website at https://fennec.mobi  (the “Website”), use our mobile application (the “App”), or engage with any of our services (collectively, the “Services,” which include the Website and App), we recognize the trust you place in us by sharing your personal information. Your privacy is of utmost importance to us. This privacy notice outlines the information we collect, how we use it, and your rights regarding your data. We encourage you to read it thoroughly, as it contains important details about your privacy. This notice applies to all information collected through our Services, including any related services, sales, marketing activities, or events.

2. Information We Collect

2.1 Personal Information

• Name
• Email address (for account creation, login, and order fulfillment)

fennec.mobi may also receive your data indirectly from the following sources:

• Google, Apple (if you create account with one of these methods)

2.2 Non-Personal Information

• fennec.mobi app version
• Device type (e.g., smartphone model)
• Operating system version
• App/website usage statistics (aggregated and anonymized)

2.3 Information We Do NOT Collect

• Browsing history
• Payment information (processed securely by third-party providers)

3. Data Controller

As the data controller, we are responsible for determining the purposes and means of processing your personal data in relation to our services, including the sale and management of eSIMs. Your data will be stored in compliance with GDPR regulations and within the EEA in Germany.

4. How We Use Your Information

How We Use Your Personal Information

We utilize your personal information for various purposes, including:

• Identifying you when you access our websites.
• Providing products and services or managing returns.
• Enhancing our services and product offerings.
• Streamlining the checkout experience.
• Conducting data analysis.
• Communicating with you to address your requests, inquiries, or feedback.
• Sending marketing and promotional content related to our products, services, sales, or those of our partners.
• Detecting and preventing malicious, fraudulent, or illegal activities, as well as ensuring compliance with our policies and protecting our rights and safety.
• Identifying and fixing errors that affect the functionality of our website and services.
• Fulfilling legal obligations, asserting our rights, and defending against legal claims.
• Managing internal operations and our relationships effectively.
• Any other purposes for which you provide consent.

While the above points explain our main reasons for collecting your information, we often have multiple purposes. For instance, when you make a purchase online, we collect your data to fulfill our contractual obligations, but we also retain it for our legitimate interests, such as addressing any post-transaction inquiries you may have. Thus, our collection and processing of your data may be based on your consent, our contractual needs, legal requirements, or our business interests.

5. Data Sharing

We may share your personal information in various situations, including:

• With Service Providers: We may share your personal data with third-party service providers who assist us in various functions, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. These providers are required to protect your information and can only use it for the purposes specified in our agreements.
• For Legal Compliance: We may disclose your information if required to do so by law or in response to valid requests from public authorities, such as a court, government agency, or regulatory body. This includes sharing information to comply with subpoenas, court orders, or other legal processes.
• To Protect Our Rights and Safety: We may share your information when we believe it is necessary to investigate, prevent, or take action regarding possible violations of our policies, suspected fraud, or situations involving potential threats to the safety of any person. This may include sharing your information with law enforcement agencies or other relevant authorities.
• With Your Consent: We may share your personal information with third parties if you have provided explicit consent for us to do so. This could include sharing your information with partners for joint marketing efforts or other purposes you agree to.
• Aggregated or De-Identified Information: We may share aggregated or de-identified data that cannot be used to identify you. This information may be shared with third parties for various purposes, including research, analytics, or marketing. By using this type of information, we ensure that it cannot be linked back to you personally.
• In Connection with Promotions: If you participate in contests, sweepstakes, or promotions, we may share your information with third parties involved in those activities, including sponsors and service providers. We will ensure that you are informed about how your information will be used in these contexts.

We are committed to protecting your privacy and ensuring that any sharing of your personal information is conducted in compliance with applicable laws and regulations. We take appropriate measures to safeguard your information and limit its use to the purposes outlined above.

6. Security Measures

• Data Encryption: We use encryption technologies to protect your personal data during transmission and storage. This ensures that your information is secure and cannot be easily accessed by unauthorized parties.
• Access Controls: Access to your personal information is restricted to authorized personnel only. We implement strict access control measures to ensure that only those who need to know your information for legitimate purposes have access to it.
• Regular Security Audits: We conduct regular security audits and assessments to identify potential vulnerabilities in our systems. This proactive approach helps us enhance our security measures and protect your information.
• Firewalls and Intrusion Detection Systems: We employ firewalls and intrusion detection systems to monitor and protect our networks from unauthorized access and malicious activities.
• Employee Training: Our employees receive training on data privacy and security practices. We emphasize the importance of safeguarding personal information and maintaining confidentiality.
• Incident Response Plan: In the event of a data breach or security incident, we have established an incident response plan to quickly address and mitigate any risks to your personal information.
• Third-Party Security Assessments: We evaluate the security practices of third-party service providers to ensure they meet our security standards before sharing any personal information with them.

7. Your Rights

You have certain rights regarding your personal information under applicable data protection laws. These rights may include:

• The Right to Access: You have the right to request access to the personal information we hold about you. This allows you to verify the information we process and understand how we use it.
• The Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information we hold about you. We strive to ensure that your information is accurate and up to date.
• The Right to Erasure: You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent on which the processing is based.
• The Right to Restrict Processing: You have the right to request the restriction of processing your personal information under certain circumstances, such as if you contest the accuracy of the information or object to its processing.
• The Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.
• The Right to Object: You have the right to object to the processing of your personal information based on legitimate interests or for direct marketing purposes. If you exercise this right, we will cease processing your information for those purposes.
• The Right to Withdraw Consent: If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the contact information provided in this privacy policy. We will respond to your request in accordance with applicable laws and regulations.

8. International Transfers

Data may be processed in countries with different privacy laws. We ensure adequate protection through Standard Contractual Clauses or other legal mechanisms.

To provide our services, your personal information may be shared with trusted third parties, including service providers, telecom partners, and legal authorities. These parties assist us in processing payments, delivering eSIMs, and complying with legal obligations. We ensure all third parties adhere to strict data protection standards and use your information only for the purposes outlined in this policy.

As a global eSIM provider, your data may be transferred to and processed in countries outside your jurisdiction, including countries that may not have the same data protection laws as your home country. When such transfers occur, we implement appropriate safeguards to protect your information. These safeguards include Standard Contractual Clauses (approved by the European Commission) or other legally recognized mechanisms to ensure your data is handled securely and in compliance with applicable laws.

By using our services, you consent to the transfer of your data to these countries and third parties as described in this policy. If you have any questions about international data transfers, please contact us at support@fennec.mobi.

9. How Long Do We Retain Your Personal Data?

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention period depends on the type of data and the purpose for which it is processed.

For example, we retain your account information (such as your email address) for as long as your account is active. If you close your account, we will delete your personal data within 30 days, unless we are required to retain it for legal, regulatory, or fraud prevention purposes.

Transactional data, such as payment information and order history, is retained for a period of 7 years to comply with financial and tax regulations. Aggregated and anonymized data, which cannot be used to identify you, may be retained indefinitely for analytical purposes.

If you have any questions about our data retention practices or wish to request the deletion of your personal data, please contact us at support@fennec.mobi.

10. Children

Our services are not intended for individuals under the age of 18 (or the legal age of majority in your jurisdiction). We do not knowingly collect, use, or disclose personal information from children without verifiable parental consent.

If we become aware that we have collected personal information from a child without parental consent, we will take immediate steps to delete such information from our systems. If you believe that we may have collected information from a child, please contact us at support@fennec.mobi, and we will promptly address the issue.

Parents or guardians who wish to review, delete, or restrict the use of their child’s personal information can contact us using the information provided above. We are committed to protecting the privacy of children and complying with applicable laws, such as the Children’s Online Privacy Protection Act (COPPA) in the United States and the General Data Protection Regulation (GDPR) in the European Union.

11. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the "Effective Date" at the top of this policy and, if the changes are significant, we will provide a more prominent notice, such as an email notification or a banner on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

If you have any questions about the changes or this Privacy Policy in general, please contact us at support@fennec.mobi.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please feel free to contact us. We are here to assist you.

You can reach us via:

• Email: support@fennec.mobi
• Phone: +852 4626 9096

We will respond to your inquiries as soon as possible and aim to resolve any issues promptly. Your privacy is important to us, and we are committed to addressing your concerns with care and diligence.