Privacy Policy

LL-DC – Diaspora Connect GmbH (in formation)

Zurich, Switzerland

legal@ll-dc.app

• Account and order data — name, billing email, billing country, language preference, plans purchased, transaction reference.
• Payment metadata — Stripe transaction reference, authorisation status, card brand, last four digits. Full card numbers and CVV are processed by Stripe and are not transmitted to us.
• Service-delivery data — eSIM profile identifier (ICCID), activation status reported by our telecommunications partner, destination region, and the activation credentials required to install the eSIM (SM-DP+ server address, matching identifier, and any pre-rendered QR image). Activation credentials are encrypted at rest at column level and decrypted only at the moment an authenticated retrieval is made through your signed-in account.
• Support correspondence — content of messages sent to and replies issued by our support team.
• Operational logs — IP address of incoming requests, route accessed, timestamp, error code. Designed to exclude request bodies and payment fields.

The eSIM service is data-only. The content of customer communications is not processed.

• Performance of the contract (GDPR Art. 6(1)(b); FADP Art. 31) — for account, order, payment, service-delivery, and support data.
• Compliance with legal obligations (Art. 6(1)(c)) — for invoicing, accounting, and tax retention.
• Legitimate interests (Art. 6(1)(f)) — for operating the service securely and preventing abuse, balanced against customer rights.
• Consent (Art. 6(1)(a)) — for the prior express consent to begin supply of the digital content before the end of the withdrawal period, collected at checkout.

Personal data is shared only with the recipients required to operate the service.

• Payments — Stripe Payments Europe Limited (Ireland). Card transaction processed directly on Stripe.
• Account and order storage — Supabase, data resident in the Zürich region, operated by Supabase Inc. under our processing agreement.
• Application hosting — Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. Operation of the web application (rendering, routing, static assets, edge caching).
• Transactional email — Infomaniak Network SA, Geneva, Switzerland. SMTP delivery of account, order, eSIM and security-related emails. Marketing emails are not part of this processing relationship.
• Telecommunications partner — issues the eSIM profile and reports activation status. The supplier is not publicly named while the contract remains under negotiation.
• AI advisor (Concierge) — OpenAI, L.L.C. (USA). Processes only the messages you type into the chat in order to generate product-related answers. No access to account, order or payment data.
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Personal data is not shared with advertising networks, social platforms, or data brokers. Authentication is handled by software running inside our own application; sign-in credentials are not processed by a separate third party beyond the storage above.

• Infomaniak — Geneva, Switzerland. No cross-border transfer required.
• Vercel Inc. — Application hosting and audience measurement in the United States. Transfer safeguarded by the EU Standard Contractual Clauses under the Vercel Data Processing Addendum.
• Stripe Payments Europe Limited — Ireland (EEA). Stripe transfers limited payment data to its affiliates outside the EU/EEA, including Stripe, Inc. (United States), under the EU Standard Contractual Clauses and the Swiss addendum.
• Supabase — data resident in the Zürich region. The operating company is based in the United States; administrative access is governed by our processing agreement and, where required, the EU Standard Contractual Clauses with the Swiss addendum.
• AI advisor — OpenAI, L.L.C., United States. Chat inputs are transferred under the EU Standard Contractual Clauses; content is not used to train the models.

Personal data is not transferred to any other jurisdiction without an applicable safeguard.

• Account data — for the duration of the customer relationship plus 12 months, unless earlier deletion is requested.
• Order, billing, and payment-reference data — 10 years (Swiss CO Art. 958f accounting retention).
• Service-delivery data — for the duration the corresponding order record is retained.
• Support correspondence — 24 months from the last message in the thread.
• Operational logs — 90 days, then automatically deleted.

You have the right to access, correct, delete, restrict, or object to processing of your personal data, to receive a portable copy, and to withdraw any consent previously given. You also have the right to lodge a complaint with your data-protection authority — for residents of Switzerland, the Federal Data Protection and Information Commissioner (FDPIC, Berne); for residents of the EU, the national supervisory authority of your country.

To exercise these rights, write to privacy@ll-dc.app. Requests are handled within the GDPR one-month deadline.

The eSIM profile attaches to networks operated by our telecommunications partner and the underlying mobile network operators in the destination country. The partner and the local operators process technical traffic data necessary to operate the radio network and to meet local regulatory requirements, including statutory call-data-record retention in some jurisdictions. Retention periods, lawful bases, and competent authorities applicable to that upstream processing are determined by the partner and the local operator.

Device compatibility is the customer's responsibility (see Terms). LL-DC does not own mobile spectrum, base stations, or a core network.

Our website offers an optional AI chat advisor that answers general questions about products, coverage, devices and setup. Use is voluntary.

• Scope — The advisor answers solely on the basis of publicly published content (FAQ, plans, compatibility). It has no access to your account, orders, payments or any other personal data.
• Data processed — Only the text you actively type into the chat, plus your language selection. This is sent to our AI provider to generate a reply.
• Storage — The conversation exists only in your browser's memory and is deleted when you close the chat. We do not store the conversation on our servers and do not link it to your account.
• Processor — Processing is carried out by OpenAI, L.L.C. (USA) as a processor under the EU Standard Contractual Clauses. Inputs are not used to train the models.
• Please note — Do not enter sensitive or personal data (e.g. passwords, full card numbers) into the chat. For account- or order-specific matters, please contact our support team.

The advisor's responses are for general guidance only and may be incomplete or inaccurate. Only the information on the plan pages and in these terms is authoritative.

The site uses only strictly necessary client-side storage:

• session and authentication storage to keep customers signed in;
• cart storage to retain a selected plan on the device;
• CSRF protection.

Stripe sets cookies on its own checkout surface for fraud prevention and session integrity, governed by Stripe's privacy policy. We do not use tracking or advertising cookies.

Personal data is protected with TLS in transit, encrypted storage at rest with our database provider, modern password hashing, role-based access controls, and audit logging of administrative actions on customer records. Activation credentials carry an additional column-level encryption envelope. Each authenticated retrieval through your account is rate-limited and recorded in an internal log for fraud and abuse prevention; the credentials are never persisted in your browser's local, session, or indexed storage. In the event of a personal data breach likely to affect customer rights, we notify affected persons and the competent authority within the GDPR Article 33 / 34 deadlines.

We may update this policy to reflect changes in the service, our recipients, or applicable law. The "last updated" date at the top of this page reflects the latest version. Material changes are communicated by email where one is on file.

Privacy enquiries: privacy@ll-dc.app.

General contact: support@ll-dc.app.

Company identification: see our Imprint.