Kebijakan Privasi

This Privacy Policy explains what personal data ArriGo collects when you visit arrigo.app (the "Website"), buy or use one of our eSIM data plans (the "Services"), place a team order, or contact us, and what we do with it. It applies whatever device you use.

"Personal data" means any information that identifies you directly or indirectly, such as your email address, an order linked to you, or your IP address.

Please read this policy together with our Terms of Service and Refund Policy. Terms with a capital letter that are not defined here have the meaning given in the Terms of Service. By using the Website or the Services, you acknowledge that your personal data is processed as described below. If you do not agree, please do not use the Website or the Services.

Who we are

ArriGo is operated by Starvane ("Starvane", "we", "us", "our"). Starvane is responsible for your personal data collected through arrigo.app: we are the data controller and decide why and how your personal data is processed.

Starvane is based in Canada. You can reach us about anything in this policy at support@arrigo.app. Our handling of personal information is governed by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where they apply to you, the data protection laws of your country, including the EU and UK General Data Protection Regulation.

1. The short version

• You don't create an account. To buy an eSIM we only need your email address and a payment.
• We never see your full card number. Payments are handled by Stripe.
• Your QR code and activation codes are treated like a payment token: they are sent only to you, shown only on your private order page, and never written to our logs.
• We use Google Analytics to understand how visitors use the Website. We don't use advertising cookies, and we don't sell or rent your data.
• We only send emails you need for your order. We don't send marketing emails unless you opt in.

2. Personal data we process

We collect personal data in two ways: information you give us (for example, your email at checkout) and information generated automatically when you use the Website or the Services (for example, your IP address in request logs). The data depends on how you use ArriGo.

I) When you buy an eSIM

• Contact data. Your email address. We use it to send your QR code, installation instructions and receipts, and to answer you if you write to us.
• Order data. The destination and plan you chose, price, currency, website language, order date and status, an order number, and a randomly generated, unguessable link to your private order page.
• eSIM data. The identifiers of the eSIM issued for your order: ICCID, SM-DP+ address, activation code and QR code, and the plan's status as reported by our network partner (for example, installed, in use, or expired). Anyone holding the activation code can install the eSIM, so we show it only on your order page and in the delivery email, and we never include it in logs.
• Approximate location. We don't collect your precise location. The country you buy for tells us where you plan to travel. Your browser language may be used to pre-select the website language and currency.

II) When you pay

• Payment data. You pay on a checkout page hosted by Stripe. Stripe collects your card or wallet details (Apple Pay, Google Pay), cardholder name, billing country and postcode where required, and device and IP information used for fraud prevention. We receive only a payment reference, the amount and currency, the payment status, the card brand and last four digits where Stripe provides them, and the billing details needed for the invoice. We never receive or store your full card number or security code.
• Tax data. Where tax rules require it, Stripe may ask for your billing country or address so that the correct tax can be applied.
• Refunds and disputes. If you ask for a refund or dispute a payment, we process the information in your request together with the original order and payment data, our support correspondence, and the eSIM's status from our network partner (for example, whether it was installed). We need this to assess and process the request, or to respond to the dispute.
• Fraud prevention. Stripe screens payments with its own fraud tools (Stripe Radar) using data such as your email, IP address and device information. A payment flagged as high risk may be declined.

III) When you place a team order (ArriGo for Business)

• Buyer data. Company name, billing email address, billing address, and VAT or tax ID if you provide one. Stripe collects these at checkout and shows them on the invoice.
• Team member data. The email address of each person who should receive an eSIM. If you are a team member, your employer or the person who placed the order gave us your email. We use it only to send your eSIM and installation instructions.
• Team page. The buyer receives a private link to a team page that lists each recipient's email address, delivery status, and a link to each install page. Install pages show activation codes, so the buyer is responsible for keeping that link private.

IV) When you contact us

• Support data. Your email address, the content of your messages and attachments, and the information needed to solve your request, such as your order link, phone model, the country you're in and screenshots of error messages. Please don't send us screenshots of your QR code.

V) When you visit the Website

• Request and security logs. Like most websites, our hosting provider Cloudflare processes technical data for every request: IP address, date and time, the page requested, browser and operating system (user agent) and referring page. This is needed to deliver pages, keep the service secure and reliable, and block attacks such as DDoS attempts, scanning and abuse.
• Rate limiting. To protect checkout from abuse, we keep a counter of checkout attempts per IP address. These counters are deleted automatically after 24 hours.
• Speed test. When you run the speed test at arrigo.app/speed, your browser downloads and uploads test files from Cloudflare's network, which measures the speed. When the test finishes, we save the result anonymously: download and upload speed, ping and jitter, whether you said you were on mobile data or Wi-Fi, the connection type your browser reports (if any), the device type (phone, tablet or computer), the website language, and the country and network operator that Cloudflare derives from your IP address. We don't store your IP address or anything else that identifies you, and the result can't be linked to you or to an order. To limit abuse, we count tests per IP address using a one-way hash of the address, deleted within 24 hours. We use these results only in aggregated form, to build statistics of network quality by country and operator.
• Preferences stored on your device. The Website stores your chosen theme (light or dark), language and currency in your browser's local storage, and caches the day's exchange rates for a few minutes in session storage. This information stays on your device and is not sent to us. You can clear it at any time in your browser settings.
• Content from other providers. To display the Website, your browser loads fonts from Google Fonts, flag images from flagcdn.com and photos from Unsplash. These providers receive your IP address and browser details when your browser requests the files. On your order page, the QR code image may be loaded from our eSIM partner's servers. We have set it up so that the address of your order page is not passed on.
• Website analytics. We use Google Analytics to measure visits and improve the Website: which pages are viewed, how visitors arrive (search, links), the approximate country, device and browser. These tools set cookies or similar identifiers in your browser and receive your IP address. They are not loaded on your private order page or the checkout. You can block them with your browser's tracking protection or an ad blocker, or opt out of Google Analytics with Google's browser add-on. We don't use advertising pixels or affiliate cookies.
• Stripe checkout. Stripe sets its own cookies on its checkout page (checkout.stripe.com) to process your payment and prevent fraud. They are governed by Stripe's privacy policy.

VI) Information we don't collect

Our plans are data-only. We don't issue phone numbers, so we don't process call records or SMS content. We don't see the websites you visit or the content of your internet traffic. The local network operator that carries your data, and our network partner, may process technical traffic and usage data (for example, the amount of data used and the network you connect to) under their own legal obligations. We receive only the totals needed to show your plan's status and to handle refunds. We don't ask for identity documents. If a destination's law ever requires identity checks for an eSIM, we will tell you before you buy.

3. Why we process your data and on what legal basis

• To perform our contract with you (Art. 6(1)(b) GDPR): to take your order and payment, issue and deliver your eSIM, show your order page, send service emails (receipts, delivery, important changes to your plan), provide support, and process refunds.
• To comply with legal obligations (Art. 6(1)(c) GDPR): to keep accounting and tax records, issue invoices, and respond to lawful requests from authorities.
• Based on our legitimate interests (Art. 6(1)(f) GDPR), which we have weighed against your rights:
  • to keep the Website and the Services secure, and to detect and prevent fraud, abuse and attacks (for example, logs and rate limiting);
  • to establish, exercise or defend legal claims, including payment disputes;
  • to deliver team orders, for team members whose email the buyer gave us;
  • to understand and fix technical problems and improve the Services, using aggregated order data (for example, which destinations are popular);
  • to build anonymous statistics of mobile and internet network quality by country and operator from speed test results.
• Based on your consent (Art. 6(1)(a) GDPR): to send you offers or news, only if you have opted in. You can withdraw consent at any time; this does not affect processing done before.

You need to give us your email address and make a payment to buy an eSIM. Without them, we cannot provide the Services. We don't make decisions about you based solely on automated processing that have legal or similarly significant effects, apart from Stripe's automated fraud screening of payments. If you think a payment was declined in error, contact us and a person will review it.

4. Who we share your data with

We don't sell, rent or trade your personal data. We share it only as described here.

Service providers (processors)

These companies process personal data on our behalf, follow our instructions, and are bound by data processing terms:

• Cloudflare, Inc.: website hosting, content delivery, security, and the database where orders are stored.
• Resend (Plus Five Five, Inc.): sending transactional emails, such as your QR code and receipts. Resend processes your email address and the content of the email.
• Our email hosting provider: our support mailbox at support@arrigo.app.

Independent controllers

• Stripe (Stripe, Inc. and Stripe Payments Europe, Ltd., depending on your location): payment processing, fraud prevention and invoicing. For payment data, Stripe acts as an independent controller under its own privacy policy.
• eSIM Access and the mobile network operators it works with: they issue your eSIM profile and carry your data traffic. We send them only what they need to issue the eSIM (the plan and an order reference). We don't share your email address or name with them. Network operators process technical connection data under their own obligations.
• Google Fonts, flagcdn.com and Unsplash: they receive your IP address when your browser loads fonts and images, as described in section 2(V).

Other cases

• Team orders. If someone ordered an eSIM for you, they can see your email address and delivery status on their team page.
• Authorities and legal claims. We may disclose personal data to courts, law enforcement, tax and regulatory authorities when the law requires it, or when it is necessary to establish, exercise or defend legal claims, or to investigate fraud or violations of our Terms of Service.
• Business transfers. If ArriGo is involved in a merger, acquisition, sale of assets or reorganisation, personal data may be transferred to the new owner. The new owner will remain bound by this policy, or we will notify you first.

5. International transfers

Some of our providers process data outside your country, including in Canada, the United States and, for eSIM provisioning, in Asia, where our eSIM partner operates. When personal data from the European Economic Area, the United Kingdom or Switzerland is transferred to a country without an adequacy decision, we rely on appropriate safeguards. These are the European Commission's Standard Contractual Clauses (with the UK Addendum where relevant) or the provider's certification under the EU–US Data Privacy Framework. You can ask us for a copy of the relevant safeguards.

6. How long we keep your data

We keep personal data only as long as we need it for the purposes above, or as long as the law requires:

• Orders and eSIM data (email, plan, eSIM identifiers, order page): for 3 years after the plan expires, so you can find your order, get support, and request refunds within the legal claim periods.
• Payment, invoice and accounting records: for as long as tax and accounting law requires, at least 6 years from the end of the tax year to which they relate, as required by the Canada Revenue Agency.
• Support correspondence: for 3 years after the conversation ends.
• Rate-limiting counters (IP address): deleted automatically within 24 hours.
• Speed test results: kept without a time limit, as they are anonymous and contain no personal data.
• Hosting and security logs: kept by Cloudflare for a short period, generally no longer than 30 days.
• Marketing consent (if you opted in): until you withdraw it, or 2 years after your last order, whichever comes first.

When the retention period ends, we delete the data or anonymise it so that it can no longer be linked to you. We may keep data longer if it is needed for an ongoing dispute or legal claim, until the matter is resolved.

7. How we protect your data

• All connections to the Website and our providers are encrypted with TLS (HTTPS). Data is encrypted at rest by our hosting provider.
• Order pages use long, random, unguessable links. On the order page, your email address is partially hidden.
• Activation codes and QR codes are never written to our logs. They are shown only on your order page and sent only to the recipient's email address.
• Payment webhooks are verified with cryptographic signatures. Access to the order database and admin tools is password-protected and limited to the people who need it to run the service.
• Secrets such as API keys are stored as encrypted environment variables, never in our source code.

No system is completely secure. If we become aware of a personal data breach that is likely to put your rights at risk, we will notify you and the competent authority without undue delay, as required by law. If you think your order link or codes were exposed, write to support@arrigo.app right away.

8. Your rights

Depending on where you live, data protection law gives you the following rights:

• Access: get confirmation that we process your data and a copy of it.
• Rectification: have inaccurate or incomplete data corrected. For example, if you entered your email address with a typo.
• Erasure: have your data deleted when we no longer need it or have no legal basis to keep it. We may need to keep some data, such as accounting records, for as long as the law requires.
• Restriction: ask us to limit processing while a complaint is being checked.
• Objection: object to processing based on our legitimate interests, and to direct marketing at any time.
• Portability: receive data you gave us in a structured, machine-readable format, or have it sent to another controller where technically possible.
• Withdrawing consent: at any time, for processing based on consent.
• Complaint: lodge a complaint with a data protection authority. In Canada, this is the Office of the Privacy Commissioner of Canada (priv.gc.ca); in France, the CNIL (cnil.fr); in the UK, the ICO (ico.org.uk). We'd appreciate the chance to resolve your concern first.

How to exercise your rights. Email support@arrigo.app from the address you used for your order, or include your order link. Because we don't have user accounts, we use your email address and order details to confirm that the request comes from you. We may ask for more information if we can't verify it. We reply within one month. That can be extended by two months for complex requests, in which case we'll tell you why. Exercising your rights is free unless a request is clearly unfounded or excessive.

Unsubscribing. Every marketing email has an unsubscribe link. Service emails about your order (delivery, receipts, refunds) are part of the Services and are sent regardless.

9. Country-specific information

European Economic Area, United Kingdom and Switzerland

The legal bases in section 3 and the rights in section 8 apply under the GDPR, the UK GDPR and the Swiss Federal Act on Data Protection.

United States, including California

In the past 12 months we have collected the following categories of personal information: identifiers (email address, IP address), commercial information (orders and purchase history), internet activity limited to request logs, and, for team orders, professional information (company name and billing details). We collected it for the business purposes described in section 3. We disclosed it only to the service providers listed in section 4. We do not sell or share personal information for cross-context behavioural advertising, as those terms are defined in the California Consumer Privacy Act (CCPA). We do not use sensitive personal information for purposes that would give rise to a right to limit its use. California residents may request to know, delete and correct their personal information, and will not be discriminated against for exercising these rights. An authorised agent may submit a request on your behalf if we can verify the authorisation.

Canada

We handle personal information in line with PIPEDA and applicable provincial laws. You may access and correct your personal information and withdraw consent, subject to legal or contractual restrictions, by contacting us at support@arrigo.app. If you are not satisfied with our answer, you may contact the Office of the Privacy Commissioner of Canada.

Rest of the world

You may exercise the rights available under your local data protection law by contacting us at support@arrigo.app.

10. Children

The Services are intended for people aged 18 and over, and for younger people only through a parent or guardian who places the order. We don't knowingly collect personal data from children under 16. If you believe a child has given us personal data, contact us and we will delete it.

11. Links to other websites

The Website links to other sites, such as Stripe's checkout page, the help pages of phone manufacturers and our social media profiles. These sites have their own privacy practices, which we don't control. Please read their privacy policies.

12. Changes to this policy

We may update this policy when we add features or when the law changes. The date at the top shows the latest version. If a change materially affects how we process your personal data, we will tell you in advance by email or on the Website. Unless we say otherwise, a new version applies from the date it is published.

13. Language

This policy is written in English. If we publish a translation and it differs from the English version, the English version prevails, unless mandatory law in your country says otherwise.

14. Contact us

For questions, requests or complaints about this policy or how we handle your personal data, contact us at support@arrigo.app, or write to Starvane, Canada.