Privacy Policy

Introduction

This Privacy Policy describes how Travan Inc. ("Travan," "we," "our," or "us") collects, uses, and discloses your information when you use our website, mobile application, and services (collectively, the "Services"), including eSIM data services and Call communication services. We are committed to protecting your personal information and your right to privacy. By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

If you have any questions or concerns about this Privacy Policy, or our practices regarding your personal information, please contact us at support@travanglobal.com.

Information We Collect

We collect several types of information from and about users of our Services, including:

Personal Information You Provide

• Contact information (name, email address, phone number)
• Account credentials (username and password)
• Payment information (billing address, payment method details)
• Identity verification information when required
• Communication preferences and marketing consents
• Customer support interactions and feedback

Call and Communication Data

When you use our Call and communication services, we collect:

• Call logs, including numbers dialed, call duration, and date and time of calls
• Customer Proprietary Network Information (CPNI) as defined by applicable telecommunications regulations
• Call connection quality metrics and performance data (packet loss, jitter, latency)

CPNI includes information about the quantity, technical configuration, type, destination, and amount of use of your telecommunications services. We use CPNI solely to provide and improve your Call services and to manage your account. We will not use CPNI for marketing purposes without your express prior consent.

Technical and Usage Information

• eSIM data usage statistics and connection logs
• Device information (device type, operating system, unique device identifiers)
• IP addresses and network information
• Browser type, language settings, and time zone
• App usage analytics and performance data
• Crash reports and error logs
• Access times and referring website addresses

Location Information

We may collect location information to provide our eSIM services effectively, including:

• Approximate location based on IP address for service optimization
• Country and region information for plan recommendations
• Network location data when using our eSIM services

Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and provide personalized content. You can control cookie preferences through your browser settings. We use the following types of cookies:

• Strictly necessary cookies: Required for the Services to function
• Analytics cookies: Help us understand how users interact with the Services
• Preference cookies: Remember your settings and preferences
• Marketing cookies: Used to deliver relevant promotional content (requires consent)

How We Use Your Information

We use the information we collect for the following purposes:

Service Provision

• Activate and manage eSIM profiles and data plans
• Provision and operate Call services and phone number assignments
• Process payments and manage billing
• Provide customer support and technical assistance
• Maintain and improve our Services

Communication and Marketing

• Send service-related notifications and updates
• Respond to inquiries and support requests
• Send promotional offers and product information (with consent)
• Conduct customer satisfaction surveys

Analytics and Improvement

• Analyze usage patterns and service performance
• Develop new features and improve existing ones
• Conduct research and analytics for business insights
• Personalize user experience and recommendations

Legal and Security

• Detect, prevent, and investigate fraudulent activities
• Enforce our terms and conditions
• Comply with legal obligations and regulations, including telecommunications laws
• Protect the security and integrity of our Services

Legal Basis for Processing

For users in the European Economic Area (EEA) or United Kingdom, we process your personal data on the following legal bases under the General Data Protection Regulation (GDPR):

• Performance of Contract: Processing necessary to provide the Services you have requested, including eSIM activation, Call provisioning, and payment processing.
• Legitimate Interests: Processing necessary for our legitimate business interests, such as fraud prevention, network security, service improvement, and analytics, where such interests are not overridden by your rights.
• Legal Obligation: Processing required to comply with applicable laws, including telecommunications regulations and tax obligations.
• Consent: Processing for marketing communications, non-essential cookies, and other purposes where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

How We Share Your Information

We may share your information in the following circumstances:

Service Providers

• Mobile network operators and telecommunications partners (receive minimal technical data only, such as network identifiers; they do not receive your name, email, or payment information)
• Payment processors and financial service providers
• Cloud hosting and infrastructure providers
• Customer support and analytics services
• Marketing and communication platforms

Legal Requirements

• When required by law, regulation, court order, or legal process
• To protect our rights, property, or safety
• To enforce our terms and conditions
• In response to lawful government or regulatory requests

Business Transfers

In connection with any merger, acquisition, financing, or sale of assets, we may transfer your information to the relevant third parties, subject to standard confidentiality protections.

With Your Consent

We may share your information for other purposes with your explicit consent.

We do not sell your personal information to third parties for their own commercial purposes.

Your Privacy Rights

Depending on your location, you may have the following rights:

General Rights

• Request access to your personal information and receive a copy in a portable format
• Update or correct inaccurate personal information
• Request deletion of your personal information
• Restrict or object to certain processing activities
• Opt out of marketing communications
• Manage cookie and tracking preferences
• Control push notifications and alerts

European Economic Area (EEA) and UK Rights (GDPR)

If you are located in the EEA or UK, you have the following additional rights under the GDPR:

• Right to be informed about how your data is used
• Right to erasure ("right to be forgotten") in certain circumstances
• Right to restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interests
• Rights related to automated decision-making and profiling
• Right to lodge a complaint with your local data protection supervisory authority

California Residents (CCPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA:

• Right to know what personal information we collect, use, and disclose
• Right to delete personal information we have collected about you
• Right to correct inaccurate personal information
• Right to opt out of the sale or sharing of personal information (we do not sell personal information)
• Right to limit the use of sensitive personal information
• Right to non-discrimination for exercising your privacy rights

To exercise your California privacy rights, contact us at support@travanglobal.com. We will respond to verified requests within 45 days.

To exercise any of your privacy rights, please contact us at support@travanglobal.com. We will respond to your request within the timeframes required by applicable law (generally within 30 days).

Data Retention

We retain your personal information for as long as your account is active and as necessary to provide our Services.

Account deletion: When you delete your account, we permanently delete your personal data — including your profile, eSIM plans, transaction history, call logs, contacts, and verified phone number — except as described below for anti-abuse purposes. Active eSIMs are blocked and your newsletter subscription is removed. This action is irreversible.

Limited retention for anti-abuse purposes: Following account deletion, your email address is retained in only one place: a separate anti-abuse registry, for a maximum of two (2) years, after which it is automatically purged. This minimal record is used solely to detect re-signups and prevent abuse of our new-user promotions — specifically, to ensure that accounts created using a previously-deleted email address are not granted the elevated first-purchase cashback rate or referral attribution. This retained email is not used for marketing, profiling, or any other purpose, and is accessible only to system administrators.

Historical referral records — covering bonuses already paid to the inviter at the time of the original purchase — are retained for accounting integrity, but your email address is removed from these records immediately upon account deletion. After deletion, only non-identifying information (the inviter's user ID, the bonus amount, and the timestamp) remains.

While your account is active:

• Account and transaction data: Retained for the lifetime of your account
• Call logs: Retained for the lifetime of your account
• Marketing preferences: Until you opt out
• Usage analytics (aggregated and anonymized): May be retained indefinitely as it cannot be used to identify you

Certain anonymized or aggregated data that cannot identify you may persist after account deletion for analytics purposes.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where our servers are located.

For transfers of personal data from the EEA, UK, or other jurisdictions with data transfer restrictions, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or other transfer mechanisms permitted under applicable data protection law. By using our Services, you acknowledge that your data may be transferred to and processed in countries outside your jurisdiction.

Data Security

We implement comprehensive security measures to protect your information, including:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication requirements
• Employee training on data protection
• Incident response and breach notification procedures

However, no internet transmission or electronic storage is completely secure. We cannot guarantee absolute security but are committed to protecting your information using industry-standard practices.

Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we learn we have collected personal information from someone under 18, we will promptly delete that information. If you believe a minor has provided us with personal information, please contact us immediately at support@travanglobal.com.

Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with external services. This Privacy Policy does not apply to these third-party services. We encourage you to review the privacy policies of any third-party services you access through our platform.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated Privacy Policy on our website and updating the "Last Updated" date. For significant changes, we may provide additional notice through email or in-app notifications.