Privacy Policy
TOORX LTD, doing business as voyasim ("voyasim," "we," "us," or "our"), recognizes the importance of your privacy. This Privacy Policy describes how we collect, use, share and protect your personal information, also known as personal data. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.
By registering an account or otherwise using or visiting any voyasim website, application, product, software, tool, data feed, and/or service (collectively the "Service"), you understand and agree to the terms of this policy.
Table of Contents
- 1. Applicability of this Privacy Policy
- 2. How We Collect, Disclose, and Use Personal Information
- 3. Information We Collect
- 4. Data Retention
- 5. How We Use Information
- 6. How We Share Personal Information
- 7. Your Rights
- 8. Data Transfer & International Data Transfer
- 9. Security
- 10. Changes to This Policy
- 11. Children
- 12. Contact Information
- 13. Google Play Billing and In-App Purchases
- 14. Additional Information for California Residents
- 15. Additional Information for Virginia Residents
- 16. Additional Information for EU Residents (GDPR)
- 17. Additional Information for Brazil Residents (LGPD)
1. Applicability of this Privacy Policy
This Privacy Policy applies to users of voyasim's services globally, including users of voyasim's mobile applications, Partner Platform, websites, features, or other services, interactions (online and offline) with voyasim, employees, and job applicants (the "Services").
This Privacy Policy specifically applies to:
- End Users: Individuals who use and interact directly with Services via their voyasim account for their personal use.
- Business Users: voyasim 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 voyasim account owners.
2. How We Collect, Disclose, and Use Personal Information
Data Controller: TOORX LTD, doing business as voyasim, is the data controller responsible for the collection, processing, and protection of your personal information. We determine the purposes and means of processing your personal data.
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.
Legal Basis for Processing Personal Data
We process your personal data based on the following legal grounds:
- Consent: We process your personal data when you have given us your explicit consent, such as for marketing communications, cookies, and contact list access.
- Contract Performance: We process your personal data to fulfill our contractual obligations to you, such as providing our services, processing payments, and managing your account.
- Legitimate Interest: We process your personal data based on our legitimate interests, such as improving our services, preventing fraud, ensuring security, and conducting business operations.
- Legal Obligation: We process your personal data to comply with applicable laws, regulations, and legal requirements, such as tax obligations and regulatory compliance.
- Vital Interests: In rare circumstances, we may process your personal data to protect your vital interests or those of another person.
You have the right to withdraw your consent at any time where we rely on consent as the legal basis for processing. You also have the right to object to processing based on legitimate interests. For more information about your rights, please see Section 7.
3. Information We Collect
Account Registration
We collect your name and contact information, including email and phone number, when you create an account. We also collect information relating to the actions that you perform while logged into your account.
Payment Information
We collect your name, billing address, shipping address, email address, phone number, and payment card number when you place an order.
Usage Data
We collect information about how you use our services (usage time, accessed features).
Device Information
We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.
Phone Number Collection
We collect your phone number for account verification, customer support, and service delivery purposes. Your phone number may be used for two-factor authentication and to send you important service notifications.
Contacts Collection
With your explicit consent, we may collect contact information from your device's contact list to enable features such as inviting friends, sharing services, or facilitating communication within our platform. We only access contacts when you grant permission and use this information solely for the intended features.
Google Play Billing and In-App Purchases
When you make purchases through our mobile applications, we use Google Play Billing services to process your payments. We collect and process the following information related to your purchases:
- Purchase Information: Product identifiers, purchase amounts, transaction IDs, and purchase timestamps
- Payment Method: We do not directly collect or store your payment card information. All payment processing is handled securely by Google Play Billing services
- Billing Address: If required for your purchase, we may collect billing address information
- Purchase History: We maintain records of your purchase history to provide customer support and manage your account
Your payment information is processed by Google Play Billing in accordance with Google's privacy policy and terms of service. We only receive confirmation of successful transactions and do not have access to your full payment details.
4. Data Retention
We retain your personal information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law.
5. How We Use Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites
- To provide products and services or to process returns
- To process and manage your in-app purchases and subscriptions
- To provide customer support for billing and purchase-related inquiries
- To improve our services and product offerings
- To streamline the checkout process
- To conduct analytics
- To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback
- To send marketing and promotional materials including information relating to our products, services, sales, or promotions
- To detect and protect against malicious, deceptive, fraudulent, or illegal activity
- To debug, identify and repair errors that impair existing intended functionality of our website and services
- To comply with our legal or regulatory obligations
Legal Basis for Specific Processing Activities
The following table outlines the legal basis for specific data processing activities:
| Processing Activity | Legal Basis | Purpose |
|---|---|---|
| Account Registration | Contract Performance | To provide you with our services |
| Payment Processing | Contract Performance | To fulfill your orders and process payments |
| Marketing Communications | Consent | To send you promotional materials (with your consent) |
| Analytics and Improvement | Legitimate Interest | To improve our services and user experience |
| Fraud Prevention | Legitimate Interest | To protect our users and business |
| Legal Compliance | Legal Obligation | To comply with applicable laws and regulations |
| Contact List Access | Consent | To enable social features (with your permission) |
6. How We Share Personal Information
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:
- Service Providers: We may share your information with service providers who help us to administer our website and provide services for the effective functioning of our business.
- Payment Processors: We share purchase information with Google Play Billing services to process your payments and manage your purchases. Google Play Billing handles all payment processing in accordance with their privacy policy and terms of service.
- Legal Requirements: We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.
- Business Partners: We may offer promotions with third party partners. If you decide to enter a promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them.
- Affiliates and Acquisitions: We may share information with our corporate affiliates. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company.
7. Your Rights
Depending on your location and subject to applicable law, you may have the following rights:
- Access your data: The right to request that we disclose to you the personal information we collect, use, or disclose about you.
- Verify and seek rectification: The right to request that we correct inaccurate personal information that we maintain about you.
- Have your personal information deleted: The right to request that we delete personal information that we have collected about you.
- Withdraw your consent: The right to withdraw consent where you have previously given consent to the processing of your personal information.
- Object to processing: The right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent.
- Right to know about data sales: The right to know whether your personal data is sold to third parties.
- Right to know about data sharing: The right to know whether your personal data is shared with third parties.
- Right to opt-out of data sale: The right to opt-out of allowing the "sale" of your personal data.
- Right to opt-out of targeted advertising: The right to opt-out of targeted advertising based on your personal data.
- Right to lodge a complaint: The right to lodge a complaint with a supervisory authority if you believe your privacy rights have been violated.
How to Opt-Out of Data Sale and Targeted Advertising
To opt-out of the sale or sharing of your personal data for targeted advertising purposes, you can:
- Contact us directly at [email protected]
- Use the opt-out mechanisms provided in our mobile applications
- Adjust your privacy settings in your account dashboard
- Use the "Do Not Sell My Personal Information" link on our website
How to Lodge a Complaint
If you believe that your privacy rights have been violated, you have the right to lodge a complaint with the appropriate supervisory authority in your jurisdiction. We encourage you to contact us first at [email protected] to address any concerns, but you also have the right to contact the relevant authorities directly.
For information about supervisory authorities in your region, please refer to the specific sections for EU residents (GDPR), Brazil residents (LGPD), and other applicable privacy laws in this Privacy Policy.
California Consumer Privacy Act (CCPA) Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- Right to Know: You have the right to request information about the personal data we collect, use, disclose, and sell about you.
- Right to Delete: You have the right to request deletion of your personal data.
- Right to Opt-Out: You have the right to opt-out of the sale of your personal data.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
Virginia Consumer Data Protection Act (VCDPA) Rights
If you are a Virginia resident, you have additional rights under the Virginia Consumer Data Protection Act (VCDPA):
- Right to Access: You have the right to confirm whether we process your personal data and access such data.
- Right to Correction: You have the right to correct inaccuracies in your personal data.
- Right to Deletion: You have the right to delete your personal data.
- Right to Data Portability: You have the right to obtain a copy of your personal data in a portable format.
- Right to Opt-Out: You have the right to opt-out of the processing of your personal data for targeted advertising, sale, or profiling.
8. Data Transfer & International Data Transfer
The Service is owned by voyasim and may be accessed globally. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible, we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.
9. Security
We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security.
10. Changes to This Policy
We reserve the right to change the terms of this Privacy Policy at any time. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email.
11. Children
Our Services are not intended for children under the age of 13 and we do not knowingly collect personal information from children under age 13, without parental consent. Children under the age of 13 should not provide their personal information to us.
12. Contact Information
Contact Us
Data Controller: TOORX LTD
Registered Address: 71 - 75 Shelton Street, London, UK, WC2H 9JQ
Phone: +994507278761
Email: [email protected]
Data Protection Officer: [email protected]
Data Controller Information
TOORX LTD is the data controller responsible for the collection, processing, and protection of your personal information. As the data controller, we determine the purposes and means of processing your personal data.
You can contact our Data Protection Officer directly for any privacy-related inquiries, requests to exercise your rights, or to report privacy concerns at:
- Email: [email protected]
- Postal Address: Data Protection Officer, TOORX LTD, 71 - 75 Shelton Street, London, UK, WC2H 9JQ
For general customer support and account-related inquiries, please contact us at [email protected].
If you have any questions, comments, appeals, or complaints concerning our privacy practices, please contact us using the information above.
13. Google Play Billing and In-App Purchases
Our mobile applications use Google Play Billing services for processing in-app purchases and subscriptions. When you make purchases through our apps:
- Payment Processing: All payment processing is handled securely by Google Play Billing services. We do not directly collect, store, or process your payment card information.
- Purchase Data: We receive and store purchase confirmation data including product identifiers, transaction amounts, and timestamps to manage your account and provide customer support.
- Subscription Management: We use Google Play Billing to manage your subscriptions, including renewal processing and cancellation requests.
- Refunds: Refund requests for in-app purchases are processed through Google Play Billing in accordance with Google's refund policies.
For questions about Google Play Billing or to manage your payment methods, please visit Google Play's payment center or contact Google Play support directly.
14. Additional Information for California Residents
California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.
California Shine the Light: If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
15. Additional Information for Virginia Residents
If you are a Virginia resident, you have additional rights under the Virginia Consumer Data Protection Act (VCDPA) as outlined in Section 7 of this Privacy Policy.
16. Additional Information for EU Residents (GDPR)
If you are a resident of the European Union, you have additional rights under the General Data Protection Regulation (GDPR):
- Right to Access: You have the right to obtain confirmation of whether we process your personal data and, where we do, access to the personal data and information about the processing.
- Right to Rectification: You have the right to have inaccurate personal data rectified and incomplete personal data completed.
- Right to Erasure: You have the right to have your personal data erased in certain circumstances.
- Right to Restrict Processing: You have the right to restrict the processing of your personal data in certain circumstances.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
- Right to Object: You have the right to object to the processing of your personal data in certain circumstances.
- Rights in Relation to Automated Decision Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
GDPR Legal Basis Information
Under GDPR, we process your personal data based on the following legal grounds:
- Article 6(1)(a) - Consent: For marketing communications and optional features
- Article 6(1)(b) - Contract Performance: For providing our services and processing payments
- Article 6(1)(c) - Legal Obligation: For compliance with applicable laws
- Article 6(1)(f) - Legitimate Interest: For business operations, security, and service improvement
Right to Lodge a Complaint with Supervisory Authority
If you are a resident of the European Union, you have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.
You may lodge a complaint with the following supervisory authorities:
- United Kingdom: Information Commissioner's Office (ICO) - https://ico.org.uk
- Ireland: Data Protection Commission - https://www.dataprotection.ie
- Germany: Federal Commissioner for Data Protection and Freedom of Information - https://www.bfdi.bund.de
- France: Commission Nationale de l'Informatique et des Libertés (CNIL) - https://www.cnil.fr
- Spain: Agencia Española de Protección de Datos (AEPD) - https://www.aepd.es
For a complete list of EU supervisory authorities, please visit: https://edpb.europa.eu/about-edpb/board/members_en
To exercise your GDPR rights, please contact us at [email protected]. We will respond to your request within one month of receipt.
16. Additional Information for Brazil Residents (LGPD)
If you are a resident of Brazil, you have additional rights under the Lei Geral de Proteção de Dados (LGPD):
- Right to Confirmation and Access: You have the right to obtain confirmation of the existence of processing of your personal data and access to the data.
- Right to Correction: You have the right to correct incomplete, inaccurate, or outdated personal data.
- Right to Anonymization, Blocking, or Deletion: You have the right to request the anonymization, blocking, or deletion of unnecessary or excessive personal data or data processed in noncompliance with the LGPD.
- Right to Data Portability: You have the right to receive your personal data in a structured and interoperable format for transfer to another service or product provider.
- Right to Information: You have the right to be informed about the public and private entities with which we have shared your personal data.
- Right to Revoke Consent: You have the right to revoke consent at any time.
Right to Lodge a Complaint with Brazilian Authorities
If you are a resident of Brazil, you have the right to lodge a complaint with the National Data Protection Authority (Autoridade Nacional de Proteção de Dados - ANPD) if you consider that the processing of your personal data infringes the LGPD.
You can contact the ANPD at:
- Website: https://www.gov.br/anpd
- Email: [email protected]
To exercise your LGPD rights, please contact us at [email protected]. We will respond to your request within 15 days of receipt.
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