Privacy supplement – eSIM service
Version: WINGS-ESIM-2026-10-10-v1 · effective 2026-10-10
SHA-256: 75cee27579d7ed855a0ccd254c41da919a6c9ec93f3374f6d3fedbf433a9bf7a
What data and why
Controller: WINGS sp. z o.o., office@wingsbrand.com. This supplement covers the eSIM service only and does not change the general WINGS privacy policy.
We process: your email and order data from the Shopify checkout, the plan, payment and fulfilment status, eSIM profile identifiers and the accepted terms version and declarations. Purposes: concluding and performing the contract (Art. 6(1)(b) GDPR), legal obligations such as tax and complaints (c), and handling requests and defending claims (f).
Activation data (QR/LPA) is stored encrypted and provided only via a private link.
Recipients (processors)
Shopify – checkout and payment; the technical eSIM provider – profile generation (your email is not shared with it); Lovable – application hosting, database and transactional email delivery.
We do not use eSIM order data for advertising.
Retention and rights
We keep data for legally required periods (incl. tax) and until claims are time-barred. You have the right of access, rectification, erasure, restriction, portability, objection and to complain to the Polish supervisory authority (UODO).