Privacy Policy
1. Introduction
This Privacy Policy ("Policy") explains how KINGSLEY AVENUE LTD (Company number 09955507), with its registered office at Ormond House 26/27 Boswell Street, Suite 2, London, England, United Kingdom, WC1N 3JZ (hereinafter "MobileXY", "we", "us", or "our"), collects, uses, stores, and protects your personal data when you use our services, including the MobileXY application, eSIM profiles, and data plans (collectively, "Services").
We are committed to protecting your privacy and will only process your personal data in accordance with this Policy, the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and other applicable data protection laws.
By using our Services, you acknowledge that you have read and understood this Policy.
2. Key Definitions
● "Personal Data": Any information relating to an identified or identifiable natural person.
● "Processing": Any operation performed on Personal Data, such as collection, storage, use, or disclosure.
● "Controller": KINGSLEY AVENUE LTD, which determines the purposes and means of processing your Personal Data.
● "You" / "Your": Any user of our Services, including visitors to our website mobilexy.com.
3. Data We Collect and How We Use It
We collect and use your Personal Data for specific, legitimate purposes, as outlined below.
|
Categories of Personal Data |
Purposes of Processing |
Legal Basis for Processing |
|
Account & Registration Data (e.g., name, email address, payment method details). |
To create and manage your account; to provide our Services; to process payments; to communicate with you about your account. |
Performance of a contract; Legitimate interests (for customer support and service administration). |
|
Technical & Usage Data (e.g., IP address, device type, browser type, app usage data, cookies). |
To ensure the technical functionality of our Services; to analyse and improve our Services; for security and fraud prevention. |
Legitimate interests (to maintain and improve our services and security). |
|
Communication Data (e.g., content of your emails, support chats, or feedback). |
To respond to your inquiries and provide customer support. |
Legitimate interests (to manage customer relationships). |
|
eSIM & Service Usage Data (e.g., data consumption, countries of use, virtual number usage). |
To deliver and configure the Services you purchase; for billing purposes; to troubleshoot technical issues. |
Performance of a contract. |
|
Marketing Data (e.g., your preferences for receiving marketing communications). |
To send you promotional offers and updates about our Services (with your consent). |
Consent (which you can withdraw at any time). |
4. How We Share Your Personal Data
We may share your Personal Data with the following categories of recipients:
● Service Providers: Trusted third parties who assist us in providing our Services, such as payment processors, cloud hosting providers, and customer support platforms. These partners are bound by strict data processing agreements.
● Network Operators: Partner mobile network operators globally to provide you with connectivity. We only share pseudonymised data (e.g., a unique identifier) necessary for the network to function, not your identifying information like your name or email.
● Legal and Regulatory Authorities: Where we are required to do so by law, or to protect our rights, property, or safety, or that of our users or others.
● Professional Advisers: Such as lawyers and accountants, where necessary.
We do not sell your Personal Data to third parties.
5. International Data Transfers
Our Services rely on partner networks worldwide. This means your pseudonymised usage data may be transferred outside the UK. When we do so, we ensure appropriate safeguards are in place, such as relying on UK adequacy regulations or using standard contractual clauses approved by the UK government.
6. Data Security
We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, and secure server infrastructure.
7. Data Retention
We will retain your Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or legal obligations). When your data is no longer needed, it will be securely deleted or anonymised.
8. Your Data Protection Rights
Under UK data protection law, you have the following rights:
● Right of Access: You can request a copy of the Personal Data we hold about you.
● Right to Rectification: You can request correction of inaccurate or incomplete data.
● Right to Erasure ('Right to be Forgotten'): You can request deletion of your Personal Data in certain circumstances.
● Right to Restrict Processing: You can request that we temporarily halt the processing of your data.
● Right to Data Portability: You can request a machine-readable copy of your data to transfer to another service.
● Right to Object: You can object to processing based on our legitimate interests.
● Rights related to automated decision-making: We do not use fully automated decision-making that produces legal effects.
To exercise any of these rights, please contact us at support@mobilexy.com. We will respond to your request within one month.
9. Cookies and Similar Technologies
Our website and app use cookies and similar tracking technologies to enhance your experience, analyse usage, and for marketing purposes. You can manage your cookie preferences through your browser settings.
10. Children's Privacy
Our Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Data from children. If we become aware that we have collected such data, we will take steps to delete it.
11. Changes to This Policy
We may update this Policy from time to time. The "Last Updated" date at the top of this page will indicate when changes were made. We will notify you of any material changes via email or a prominent notice within our Services.
12. Contact Us
If you have any questions, concerns, or complaints about this Policy or our data practices, please contact us at:
Data
Protection Officer
KINGSLEY AVENUE LTD
Ormond House 26/27 Boswell Street, Suite 2
London, England, WC1N 3JZ
Email: support@mobilexy.com
If you are not satisfied with our response, you have the right to lodge a complaint with the UK supervisory authority:
Information
Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: https://ico.org.uk/make-a-complaint/
Phone: 0303 123 1113
Last Updated: 25 November 2025