holiday.com is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your personal data when you use our website, app, and eSIM services.
1. Who Controls Your Data?
holiday.com is the sole data controller for all personal data collected through our services.
Our connectivity partner, Telna Inc., or network carries are not a data controller. Telna only processes non-attributable eSIM traffic data (e.g. network usage, performance metrics) strictly for operational purposes. This data cannot be linked to any individual user.
2. What Data We Collect and Why
We collect personal and technical data to provide and improve our services. Here's a breakdown:
| Category | Examples | Purpose |
|---|---|---|
| Customer Information | Name, email, billing address, payment details | To process purchases, manage accounts, and provide support |
| Device Information | Device type, OS, browser, IP address, location | To optimize website performance and troubleshoot issues |
| eSIM Identifiers | ICCID, IMSI, IMEI | To activate and manage your eSIM profile |
| Website Usage Data | Page views, clicks, session duration | To analyze user behavior and improve user experience |
| Communications | Support messages, feedback | To respond to inquiries and improve customer service |
| Cookies & Analytics | Google Analytics data, cookie preferences | To understand site usage and personalize content |
3. How We Use Your Data
We use your data to:
- Provide and manage eSIM services
- Process payments and issue invoices
- Respond to customer inquiries
- Improve our website and user experience
- Comply with legal obligations
We do not use eSIM identifiers for marketing or profiling.
4. Data Sharing
| Recipient | Purpose | Privacy Policy |
|---|---|---|
| Payment Processors (Apple Store, Google Play) | To process payments and complete secure transactions. | Apple Privacy Policy Google Privacy Policy |
| Customer Support Platforms (e.g., Zendesk) | To manage customer inquiries, support tickets, and related communications. | Zendesk Privacy Policy |
| Legal Authorities | If legally required, we may disclose data to comply with applicable laws or lawful requests. | N/A |
| Analytics & Tracking Providers (Google Analytics, Mixpanel, Impact Radius) | To analyze usage behavior via cookies and SDKs. Only anonymized technical data is collected. IPs are parsed into location data and discarded. | Google Privacy Policy Mixpanel Privacy Policy Impact Radius Privacy Policy |
All third-party service providers engaged by holiday.com are contractually obligated to implement and maintain appropriate technical and organizational measures to ensure the security, confidentiality, and integrity of any personal data they process on our behalf. These providers are granted access to personal data solely to the extent necessary to perform their designated functions, and are expressly prohibited from using such data for any other purposes, including for their own commercial benefit. These obligations are governed by written data processing agreements that comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) where applicable.
5. App & Website Analytics Tracking
We are implementing enhanced tracking capabilities on both our website and mobile app to improve our service delivery and user experience. This includes the use of Mixpanel’s web SDK on the website and Mixpanel’s iOS SDK in our mobile app.
5.1 Tracked Events and Parameters
We track anonymous user interactions including, but not limited to:
Events: Screen views, button clicks, navigation
Parameters:
- Anonymous user ID (not tied to PII)
- IP-derived location (country, region, city — IP is not stored)
- Device and operating system information
- App version and build
- Website referrer and UTM parameters
- Plan selection and usage data
- Mixpanel default properties (see full list here)
5.2 Affiliate Tracking
For affiliate marketing purposes, we integrate with Impact Radius using their universal tracking tag. This creates first-party cookies that help track conversions and affiliate attribution in accordance with Impact’s cookie policy.
All tracking mechanisms are implemented in compliance with applicable data protection laws. Data collected through these methods is used strictly for analytics and service improvement purposes, and never for profiling or direct marketing without your consent.
6. Cookies and Tracking
We use cookies and tracking technologies, including Google Analytics and Mixpanel, to better understand user behavior across our website and app. These tools help us analyze screen views, clicks, and usage patterns, while collecting technical data such as:
- Anonymized user ID (not linkable to PII)
- Parsed IP location (country, region, city)
- Operating system and version
- Browser and browser version (website)
- App version, build number, and OS version (app)
- Device type and screen resolution
- Referrer URLs and UTM parameters
- Plan information (e.g., selected country, duration, usage in GB)
On the website, Mixpanel uses standard first-party cookies like distinct_id to distinguish visits. In the iOS app, Mixpanel SDK collects similar default properties as listed in Mixpanel’s documentation.
You can manage cookies via browser settings and opt-out of certain analytics as described in the respective privacy policies of these services.
7. International Data Transfers
Some data may be processed outside the European Economic Area (EEA). We ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.
8. Your Rights
Depending on your location, you may have the right to:
- Access your data
- Correct inaccurate data
- Request deletion
- Object to processing
- Restrict processing
- Request data portability
To exercise these rights, contact us at dpo@holiday.com.
9. Data Retention
We retain personal data only as long as necessary for the purposes outlined above. Once no longer needed, data is securely deleted or anonymized.
10. Security Measures
We implement technical and organizational measures to protect your data. However, no system is 100% secure, and we encourage you to use strong passwords and secure devices.
11. Third-Party Links and Automated Decisions
Our website may contain links to external sites. We are not responsible for their privacy practices. Please review their policies before sharing personal data.
We do not use automated decision-making that produces legal or similarly significant effects on users. If this changes, we will update this policy and provide appropriate safeguards.
12. Updates to This Policy
We review this Privacy Policy annually and whenever there are changes in our data practices or legal obligations.
We may update this Privacy Policy periodically. Changes will be posted on this page with an updated effective date.
13. Contact Us
If you have questions or concerns about this Privacy Policy, reach out to:
Email: dpo@holiday.com