privacy
policy.

CIELO CELL LTD is responsible for the personal data processed in operating CieloCell. We are registered in England and Wales under company number 17240303. Our full postal contact details are provided at the end of this policy. This policy explains how we handle personal data through our app, website, eSIM and data services, ads, tasks and support. Contact privacy@cielocell.com with a privacy question or request.

Most of this information comes directly from you or from your use of the app. Some comes from the partners that help us run the service, as explained in each row.

Support messages and task responses can contain whatever you choose to include, so please share only what is needed.

We use the data categories described in section 02 for the following purposes. Where we rely on legitimate interests, we have checked that they are not outweighed by your interests and rights; where we rely on consent, you can withdraw it at any time.

We use contact details for necessary account and service messages, such as installation information and support replies. Promotional communications are handled according to the rules and choices applicable to you.

We share the relevant information with providers that support sign-in, eSIM connectivity, payments, technical operations, customer support, advertising and tasks. The table below explains which categories receive which information and why. Most providers act on our instructions; some advertising and task partners process information for their own purposes, as explained in the partner details below.

advertising and task partner details

The following advertising partners process information from the CieloCell app as described above. Where a partner relies on your consent, you are asked in the app before that processing starts. Google: information about how Google uses data is available at https://business.safety.google/privacy/. Unity: information about Unity's processing is available in its App User Privacy Policy at https://unity.com/legal/game-player-and-app-user-privacy-policy. Liftoff: Liftoff and its advertising partners use tracking technologies to collect, use and share advertising data for the purposes described above. Advertising-targeting choices are explained at https://vungle.com/opt-out/ and further information is at https://liftoff.ai/privacy-policy/. Task providers are identified in the app before you start a task, together with any additional terms and privacy information that apply to it.

CIELO CELL LTD is based in the United Kingdom, but personal data can be processed in the countries where our service providers and partners operate, including the United States and countries in the European Economic Area. Where the law requires safeguards for an international transfer, we use an applicable transfer arrangement, such as adequacy regulations or standard contractual clauses approved for the UK or the EU (with the UK addendum where needed). Contact privacy@cielocell.com for information about the safeguards that apply to a specific transfer.

We keep personal data for as long as needed for the purposes described in this policy. How long that is depends on the type of information, whether your account is active, applicable accounting and legal requirements, and any outstanding dispute or security investigation. In practice: • Account, eSIM and rewards records: while your account is open, then for a limited period to handle queries, disputes and legal obligations. • Purchase and payment records: for as long as accounting and tax law requires. • Advertising and task data: for as long as needed to credit and verify rewards and to detect fraud; partners keep the data they receive under their own retention rules. • Diagnostics and security data: for a limited period, unless needed for an ongoing investigation. • Support conversations: for as long as needed to resolve the matter and handle any follow-up. • Consent and preference records: for as long as we need to demonstrate what you chose. After account deletion we retain only information that remains necessary for those purposes, such as records required by law or needed to resolve a dispute. When information is no longer needed, we delete it or irreversibly anonymise it.

You can delete your account in the app: Profile → Settings → Delete Account. You can also contact privacy@cielocell.com to request deletion of your personal data. Deleting the app or removing the eSIM from your phone does not delete your CieloCell account. We process privacy requests within the applicable legal timeframe and explain any information that must be retained and why. Closing an account can affect access to plans and rewards. The Terms explain account closure and consumer remedies; closure does not remove statutory consumer rights.

Depending on the law that applies to you, you may have rights to access, correct, delete or receive a portable copy of personal data, restrict its use, object to certain processing, and withdraw consent where processing relies on it. Withdrawing consent does not change the lawfulness of processing already carried out. Contact privacy@cielocell.com. We may request information reasonably needed to verify your identity or clarify a request. Under UK and EEA data-protection rules we generally respond within one calendar month; lawful extensions or exceptions can apply, and we will explain them where relevant. You can complain to the UK Information Commissioner's Office at https://ico.org.uk/make-a-complaint/ or to another competent data-protection authority, such as the authority in the country where you live.

If you live in California or another US state with a comprehensive privacy law, you may have rights to know what personal information we collect, to access, correct and delete it, to receive a copy of it, and to opt out of the sale or sharing of personal information or its use for targeted advertising, subject to that law's thresholds and exemptions. Rewarded advertising in the app involves sharing advertising identifiers and related activity with advertising partners (section 04). Some state laws treat this as a “sale” or “sharing” of personal information or as targeted advertising. You can limit it through the privacy settings in the app and your device's advertising and tracking controls (section 11). To exercise a right, contact privacy@cielocell.com from the email address linked to your account. We will verify your request, respond within the time the applicable law allows, and tell you how to appeal if we decline a request where the law provides for an appeal. We will not discriminate against you for exercising your rights.

CieloCell is not directed at children, and we do not currently verify age when you sign in. If you are a parent or guardian and believe a child has created an account or provided personal data to us, contact privacy@cielocell.com; we will review the account and delete personal data where appropriate.

in the app

The app stores information on your device and uses software from the partners described in section 04 to provide its functions and, where enabled, to support ads, tasks, measurement and crash reporting. Optional processing that requires consent is controlled separately from your acceptance of the Terms: you are asked in the app, and you can review or change your choices at any time in the app's privacy settings. Location, notification and iOS tracking permissions are separate device controls that you can review in your phone's settings. On Android, you can reset or delete your advertising ID in your device's Google settings. Changing one control does not necessarily change every other choice.

on this website

We do not set analytics or advertising cookies on cielocell.com. Pages load fonts and code libraries from content-delivery services (Google Fonts and unpkg), which receive your IP address in order to deliver those files. The support chat on our homepage and help page is provided by a chat provider; the widget may store information on your device to keep a conversation going, and messages you send are processed by that provider, which may generate automated replies, and by our support team. Your browser settings let you block or delete stored data, which may affect the chat.

We use appropriate technical and organisational measures to protect personal data and limit access according to operational needs. No service can guarantee absolute security. We notify regulators and affected people where and when required by applicable law. Contact privacy@cielocell.com with a data-security concern.

The data described in this policy is processed in broadly the same way on iOS and Android. Differences you may notice: on iOS, using your advertising identifier to personalise ads across apps requires your permission through Apple's App Tracking Transparency prompt; on Android, your advertising ID is managed in your device's Google settings, where you can reset or delete it. Apple's App Store privacy labels and Google Play's data safety section present this information in each store's own format; this policy is the fuller description.

We will identify when this policy was last updated and when a change takes effect, and we will tell existing users about material changes through the app or email, except where applicable law requires a different process. Where a new use of personal data requires consent or another legal step, updating this policy alone does not replace that requirement.

CIELO CELL LTD — Privacy Company number 17240303 174 Stephendale Road, London, England, SW6 2PN, United Kingdom Privacy requests: privacy@cielocell.com Account, service and payment help: support@cielocell.com General enquiries: hello@cielocell.com UK Information Commissioner's Office: https://ico.org.uk/make-a-complaint/