For a deeper understanding of the Privacy Policy, the following terms are defined and will be referred to throughout:
In order to manage your relationship with us, we will process your personal data for different purposes, always in accordance with the provisions of the regulations, respecting your rights and with complete transparency.
Therefore, in this Privacy Policy, which you can access at any time at https://esimandorra.ad/politica-de-privadesa.html, you can consult the full details of how we use your data in the relationships we establish with you.
The main regulations governing the processing of your personal data are:
The owner of https://esimandorra.ad/ (hereinafter, the “Website”) and the mobile application (hereinafter, the “Application"), responsible for the processing of personal data, is ANDORRA TELECOM, SAU (hereinafter, "ANDORRA TELECOM"), an Andorran company, with registered office at Carrer Mossèn Lluís Pujol, 8-14, Santa Coloma, AD500 Andorra la Vella (Principality of Andorra), Tax Registration Number A-710646-J, registered in the Companies Register of the Principality of Andorra under number 15522, book S-230, folios 221-230 and Commercial Register number 925270 N.
We also inform you that the Data Protection Officer is the person responsible for ensuring the protection of your fundamental right to personal data protection at ANDORRA TELECOM. You can contact our Data Protection Officer ("DPO") to send your suggestions, queries, questions or complaints via: protecciodades@andorratelecom.ad or +376875000.
For the prepaid mobile data connectivity service, designed for non-residents, only the data strictly necessary for the provision and delivery of eSIMs and for the optional management of commercial communications is collected.
ANDORRA TELECOM will only process the following personal data:
This data is provided directly by the Customer via the online contract form and/or mobile application.
At ANDORRA TELECOM, we process Customer or User data for the provision of the service, as well as for other purposes that the Customer or User allows or authorises under the terms set out in this Privacy Policy or in the specific Conditions of each contracted Product or Service.
Additionally, during the term of the contractual relationship, other data may be incorporated for these or other purposes and, in this case, the Customer or User will be duly informed at the time of their collection, for example, through the online channel or the Application. Therefore, before carrying out any additional processing not provided for in this Policy, we will notify you in the "privacy information" or in the privacy clause of the Specific Conditions of each Product, Service, Application or form.
The Customer undertakes to ensure that all information provided to ANDORRA TELECOM for the management and contracting of Products and Services is authorised and has been obtained with the consent of the owner. ANDORRA TELECOM is not responsible for the use of false, inaccurate, incomplete or outdated data provided by the Customer.
To this end, ANDORRA TELECOM hereby informs you of the legal bases that will allow for the different types of processing:
ANDORRA TELECOM informs that for the execution of the contract signed with the Customer, it may use, among the categories of collected data, those that are necessary for the correct execution of the same. We also need to process your data in order to provide you with the best products and services of the highest quality to suit your needs, as well as to improve your experience in enjoying these products and services.
Processing your data will enable us to be more efficient and, therefore, help us to continue maintaining the highest levels of security and trust in the services we provide to you
The processing that may be necessary to fulfill this contract will be carried out for the following purposes:
Legitimate interest constitutes a legitimate basis for processing, provided that this interest in processing the Customer's data for the stated purpose is within their reasonable expectations based on their relationship as a Customer and User of ANDORRA TELECOM.
In this regard, we consider that they are covered by legitimate interest and, therefore, ANDORRA TELECOM may process the following data for each of the purposes described below:
Consent constitutes a legitimate basis for processing that will allow ANDORRA TELECOM to process the following data for each of the purposes described below, after obtaining the corresponding authorisation from the Customer or User, as appropriate.
To this end, each Customer or User will receive in advance a specific informative communication with sufficient detail regarding the processing of data for the purposes indicated below:
However, the Customer may always request, free of charge, by providing written proof of their identity, their exclusion, their non-use for direct marketing purposes, the total or partial omission of their address or other personal data, or the correction of any errors.
Consent for this processing may be withdrawn by sending the relevant notification by the means set out in the "Exercising Your Rights" section of this Privacy Policy.
ANDORRA TELECOM informs you that it will keep the personal data of the Customer or User only for the time necessary to carry out the purpose for which it was collected.
In order to ensure that personal data is adequate, relevant, and limited, ANDORRA TELECOM will retain personal data only for the period necessary to fulfill the purpose for which it was collected, taking into account the need to answer questions that may arise or resolve problems, make improvements, activate services, and comply with requirements under applicable law. This means that personal data may be retained for a reasonable period of time even after you have stopped using the services.
After this period, personal data will be blocked in all systems for the sole purpose of making it available to the competent authorities to address potential administrative or judicial liabilities and for the exercise or defense of claims. Once the blocking period for personal data has elapsed, it will be permanently deleted.
Specifically:
In order to guarantee the confidentiality and privacy of users of the eSIM Andorra service, ANDORRA TELECOM may apply data anonymisation and aggregation techniques, particularly for the purpose of compiling non-identifying statistics and improving the service.
This anonymised data may be used for purposes such as analysing the general use of the service or improving the range of digital services, ensuring that no individual can be identified.
The Customer or User may exercise their rights of access, rectification, erasure, objection, restriction of processing and portability at any time by sending a written and signed request to ANDORRA TELECOM (at Carrer Mossèn Lluís Pujol, 8-14, AD500 Andorra la Vella) or by sending an email to protecciodades@andorratelecom.ad, attaching in both cases a copy of their identification document (passport or valid official document).
They may also withdraw their consent to the processing of their data at any time, as well as object to receiving commercial communications, without this affecting the lawfulness of the processing based on the consent given prior to its withdrawal.
Your data will not be transferred to third parties, except when required by law or by a court order or public authorities with jurisdiction in the matter.
However, for the proper technical provision of the eSIM Andorra service, your data may be processed by third-party providers (such as QR code sending platforms or eSIM service managers), always under a data processing agreement in accordance with applicable legislation and with adequate security guarantees.
ANDORRA TELECOM takes all necessary technical and organisational measures to ensure a level of security appropriate to the risk of processing, including:
In the event that ANDORRA TELECOM uses technology service providers established outside the European Economic Area or Andorra, these transfers will be carried out with adequate safeguards such as standard contractual clauses approved by the European Commission and the APDA.
ANDORRA TELECOM reserves the right to amend this Privacy Policy to adapt it to new legislation or case law, as well as to industry practices. Any amendment will be announced with reasonable notice so that the Customer can be effectively informed of it.
Only the processing detailed above will be carried out. If new processing not covered by this Policy is envisaged in the future, specific information will be provided and, where appropriate, the corresponding consent will be obtained.
The eSIM Andorra service is intended exclusively for persons over the age of 18. ANDORRA TELECOM does not knowingly collect personal data from minors. If it is detected that a minor has contracted the service without authorisation, their data will be deleted immediately.
For details on the use of cookies on the eSIM Andorra service Website and Application, please consult our Cookie Policy available at https://esimandorra.ad/politica-galetes.html
The official version of the privacy policy is the one written in Catalan, which shall prevail in case of conflict or inconsistency with the translated versions.