# Privacy Policy
Last updated: 21 November 2025
This Privacy Policy explains how we, The Very Good Telephone Company Limited (VGTELCO and SimToRoam), collect, use, store and protect your personal data when you use our websites, products and services, including eSIM services sold under the brands SimToRoam and VGTELCO (together referred to as “we”, “us”, or “our”).
We are a company registered in England and Wales under company number 07724361. Our registered office is: Walkers Accountants Ltd, Suite 3, Aireside House, Aireside Business Centre, Royd Ings Avenue, Keighley, West Yorkshire, BD21 4BZ.
We are registered with the UK Information Commissioner’s Office (ICO) under registration number ZB667012.
By using our websites or purchasing our services, you agree to the collection and use of information in accordance with this Privacy Policy.
## 1. Who we are and how to contact us
**Data controller:**
The Very Good Telephone Company Limited
Registered office: Walkers Accountants Ltd, Suite 3, Aireside House, Aireside Business Centre, Royd Ings Avenue, Keighley, West Yorkshire, BD21 4BZ
ICO Registration: ZB667012
**Contact for privacy matters:**
Email: admin@vgtelco.com
If you have any questions about this policy or your data, please contact us using the details above.
## 2. What data we collect
We may collect and process the following categories of personal data:
– **Identity data** – name, title, contact details, customer ID.
– **Contact data** – email address, billing address, contact phone numbers.
– **Account data** – login details, profile information, communication preferences.
– **Transaction data** – details of products and services you have purchased, payment status, refund history (payment card data is processed by our payment providers and not stored by us in full).
– **Technical data** – IP address, device information, operating system, browser type, time zone, approximate location, and other telemetry collected via cookies and similar technologies.
– **Usage data** – information about how you use our websites, support channels and services.
– **eSIM / telecom-related data** – eSIM profile identifiers, activation status, country/region of use, network partner information, and usage information provided by our underlying carriers or service partners, where applicable.
– **Support interaction data** – emails or other communications, call notes and troubleshooting logs.
We do not intentionally collect special category data (such as health information) or data relating to children. If you believe a child has provided us with personal data without parental consent, please contact us so we can remove it.
## 3. How we collect your data
We collect data through:
– **Direct interactions** – when you register an account, purchase a product, contact support or subscribe to communications.
– **Automated technologies** – through cookies, logs and similar technologies when you use our websites and services.
– **Third parties** – including payment processors, fraud-prevention services and telecom partners who provide us with information needed to provision and manage your eSIM service.
## 4. How we use your data (lawful bases)
We will only use your personal data where we have a lawful basis to do so under UK data protection law. These include:
– **Contract** – to set up, provide and manage your eSIM and related services, process your orders, and handle support requests.
– **Legitimate interests** – to operate and improve our services, prevent fraud and abuse, maintain network and information security, and understand how our services are used.
– **Legal obligation** – to comply with laws, regulations, Ofcom requirements and law enforcement requests where applicable.
– **Consent** – where you have explicitly given consent for specific purposes (e.g. marketing communications or certain cookies).
You may withdraw consent at any time where consent is the lawful basis for processing.
## 5. Purposes for which we use your data
We use your data for purposes including:
– Creating and managing your account.
– Processing orders for eSIM profiles and related services.
– Provisioning, activating and managing your eSIM service with our network partners.
– Providing customer support and resolving technical issues.
– Handling complaints and disputes, including with our ADR provider (CISAS (Communications & Internet Services Adjudication Scheme)).
– Improving and developing our products, services and websites.
– Sending you service messages (e.g. activation instructions, important service updates).
– Sending you marketing communications where permitted by law and where you have not opted out.
– Preventing fraud, abuse and security incidents.
– Complying with our legal, regulatory and tax obligations.
## 6. Sharing your data
We may share your data with the following categories of recipients:
– **Telecom and eSIM partners** who provide underlying connectivity, roaming, eSIM platforms and network services needed to deliver your service.
– **Payment providers** and financial institutions to process payments, refunds and chargebacks.
– **IT and cloud service providers** who host our systems and provide infrastructure and tools (e.g. email, CRM, ticketing).
– **Professional advisers** such as auditors, accountants, lawyers and compliance consultants.
– **Regulators and authorities** including Ofcom, the ICO or law enforcement agencies where required by law or regulation.
– **ADR provider** – our Alternative Dispute Resolution scheme (CISAS (Communications & Internet Services Adjudication Scheme)) where a dispute is escalated in line with their rules and Ofcom requirements.
We require all third parties who process your personal data on our behalf to respect the security of your data and to treat it in accordance with the law.
## 7. International transfers
Some of our service providers and telecom partners may be located outside the UK or European Economic Area (EEA). Where data is transferred internationally, we will ensure appropriate safeguards are in place, such as:
– The destination country being recognised as providing an adequate level of protection; or
– Standard contractual clauses or other lawful transfer mechanisms.
You can contact us for more information about international transfers.
## 8. Data retention
We retain your personal data only for as long as reasonably necessary for the purposes set out in this policy, including for:
– The duration of your contract and a reasonable period thereafter.
– Compliance with legal, tax, accounting and regulatory requirements.
– Handling disputes or complaints.
When data is no longer needed, we will securely delete or anonymise it.
## 9. Your rights
Under UK data protection law you have the following rights:
– **Access** – to request a copy of the personal data we hold about you.
– **Rectification** – to request correction of inaccurate or incomplete data.
– **Erasure** – in certain circumstances, to request deletion of your data.
– **Restriction** – to request we restrict the processing of your data in certain cases.
– **Data portability** – to request a copy of your data in a structured, commonly used format.
– **Objection** – to object to processing based on legitimate interests or to direct marketing.
– **Withdraw consent** – where we rely on consent, you may withdraw it at any time.
To exercise these rights, please contact us at admin@vgtelco.com. We may need to verify your identity before responding.
If you are unhappy with how we handle your data, please contact us first so we can try to resolve the issue. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
## 10. Cookies and similar technologies
We use cookies and similar technologies to operate our websites, provide essential functionality, analyse usage and, where permitted, personalise content or marketing. For more detail, please see our separate Cookie Policy.
## 11. Changes to this policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website and will show the date of last update. We encourage you to review it periodically.
If we make material changes, we may notify you by email or through our services.
If you continue to use our services after a change takes effect, you will be deemed to have accepted the updated policy.