PRIVACY POLICY

Privacy Policy

Privacy Policy

1. Introduction

Xylen Management Ltd (“Xylen,” “Company,” “we,” “us,” or “our”) provides global telecom and connectivity solutions for the travel industry, including travel eSIMs, the Yolo Roam loyalty program, and carrier services such as A2P/P2A/P2P SMS, voice termination, and telecom testing. This Privacy Policy explains how we collect, use, share, and protect personal data when you visit xylen.net, use our services and partner/reseller portals, or otherwise interact with us as an end user, reseller, business manager, or B2B partner (including airlines, OTAs, travel agencies, and telecom carriers).

By accessing our website or using our services, you agree to the practices described in this Policy. This Policy should be read alongside our Terms and Conditions. This Policy is effective as of 21 September 2026.

2. Information We Collect

The personal data we collect depends on how you interact with us:

a) Website visitors and leads — Name, email address, company name, job title, phone number, and message content submitted through contact or demo-request forms.

b) eSIM and Yolo Roam customers/end users — Name, email address, payment and billing details, device identifiers (such as IMEI/EID), order history, and network usage data (data volume, session timestamps, and connection location) generated when an eSIM is activated and used.

c) Resellers and business managers — Account registration details, business/tax information, banking details for bonus and commission payments, sales and performance reporting data, and portal login activity.

d) B2B partners (airlines, OTAs, travel agencies, telecom carriers) — Business contact details, contractual and billing information, and, where applicable, traffic/usage data exchanged through A2P/P2A/P2P SMS, voice termination, or telecom testing services.

e) Automatically collected data — IP address, browser and device type, pages visited, referring URLs, and cookie identifiers, collected via our website and portals (SMS/Voice Portal, Yolo Roam Portal, API).

We do not knowingly collect more personal data than is necessary to provide our services.

3. How We Use Your Information

We use personal data to:

Provide, operate, and maintain our website, eSIMs, Yolo Roam, and carrier services

Create and manage reseller, partner, and portal accounts, and process API access

Process payments, invoices, and reseller bonus/commission calculations

Provide customer support, respond to inquiries, and handle complaints

Send service updates, account notices, and, where you have opted in, marketing communications about new solutions or partnership opportunities

Monitor network usage and traffic for billing, quality assurance, and troubleshooting

Detect, investigate, and prevent fraud, abuse, or unauthorized use of our services

Comply with legal, regulatory, and telecommunications obligations

Improve our website and services through aggregated or anonymized analytics

4. Legal Basis for Processing

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

Contract — to register accounts, deliver eSIMs and carrier services, and manage reseller and partner agreements

Legitimate interests — to secure our systems, prevent fraud, improve our services, and communicate with existing business contacts, balanced against your rights and interests

Consent — for optional marketing communications and non-essential cookies, which you may withdraw at any time

Legal obligation — to comply with telecommunications, tax, and consumer-protection laws

5. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

Enable core site functionality (strictly necessary cookies)

Understand how visitors use our site through analytics (e.g., page views, traffic sources)

Remember preferences and improve site performance

You can manage or disable non-essential cookies through your browser settings or, where available, our cookie consent banner. Disabling certain cookies may affect site functionality.

6. How We Share Your Information

We do not sell your personal data. We may share it with:

Telecom network and carrier partners — to activate and deliver eSIM, SMS, and voice services

Payment processors and financial institutions — to process payments, invoices, and reseller bonus payouts

IT, hosting, and portal service providers — to operate our website, API, and login portals

Business managers and resellers — limited data needed to fulfil orders or track performance

Professional advisors and regulators — where required for legal, tax, or compliance purposes

Law enforcement or courts — where required by law or to protect our rights, users, or the public

Any third party processing personal data on our behalf is bound by contractual obligations to protect it and use it only for the purposes we specify.

7. International Data Transfers

As a global telecom carrier serving airlines, OTAs, travel agencies, and mobile operators worldwide, we may transfer personal data outside the United Kingdom or European Economic Area, including to network partners and service providers in other countries.

Where we do, we rely on appropriate safeguards, such as the UK International Data Transfer Agreement or EU Standard Contractual Clauses, or transfer to jurisdictions recognized as providing adequate protection.

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, including to:

Provide ongoing services and support your account or reseller agreement

Meet tax, accounting, and telecommunications record-keeping obligations

Resolve disputes, complaints, or fraud investigations

Enforce our agreements

When personal data is no longer needed, we securely delete or anonymize it, subject to any legal retention requirements.

9. Data Security

We implement technical and organizational measures — including access controls, encryption in transit, and restricted portal access — designed to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you may have the right to:

Access the personal data we hold about you

Correct inaccurate or incomplete data

Request deletion of your data

Restrict or object to certain processing

Receive your data in a portable format

Withdraw consent at any time, where processing is based on consent

Lodge a complaint with your local data protection authority (in the UK, the Information Commissioner’s Office, ico.org.uk)

To exercise any of these rights, contact us using the details in Section 14. We may need to verify your identity before responding.

11. Children’s Privacy

Our website and services are intended for business use and are not directed at, or knowingly used by, individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can remove it.

12. Third-Party Links

Our website and communications may link to third-party sites and portals, including partner platforms, the SMS/Voice Portal, and the Yolo Roam Portal. This Policy does not apply to those third-party sites, and we encourage you to review their own privacy policies before providing personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Any changes will be posted on this page with a revised effective date. Your continued use of our website or services after changes are posted constitutes acceptance of the updated Policy.

14. Contact Information

If you have questions or concerns about this Privacy Policy or how we handle your personal data, please contact us at:

Xylen Management Ltd

Address — The Custard Factory, Zellig 206, Gibb Street, Birmingham B9 4AU, United Kingdom

Email — info@xylen.net

1. Introduction

Xylen Management Ltd (“Xylen,” “Company,” “we,” “us,” or “our”) provides global telecom and connectivity solutions for the travel industry, including travel eSIMs, the Yolo Roam loyalty program, and carrier services such as A2P/P2A/P2P SMS, voice termination, and telecom testing. This Privacy Policy explains how we collect, use, share, and protect personal data when you visit xylen.net, use our services and partner/reseller portals, or otherwise interact with us as an end user, reseller, business manager, or B2B partner (including airlines, OTAs, travel agencies, and telecom carriers).

By accessing our website or using our services, you agree to the practices described in this Policy. This Policy should be read alongside our Terms and Conditions. This Policy is effective as of 21 September 2026.

2. Information We Collect

The personal data we collect depends on how you interact with us:

a) Website visitors and leads — Name, email address, company name, job title, phone number, and message content submitted through contact or demo-request forms.

b) eSIM and Yolo Roam customers/end users — Name, email address, payment and billing details, device identifiers (such as IMEI/EID), order history, and network usage data (data volume, session timestamps, and connection location) generated when an eSIM is activated and used.

c) Resellers and business managers — Account registration details, business/tax information, banking details for bonus and commission payments, sales and performance reporting data, and portal login activity.

d) B2B partners (airlines, OTAs, travel agencies, telecom carriers) — Business contact details, contractual and billing information, and, where applicable, traffic/usage data exchanged through A2P/P2A/P2P SMS, voice termination, or telecom testing services.

e) Automatically collected data — IP address, browser and device type, pages visited, referring URLs, and cookie identifiers, collected via our website and portals (SMS/Voice Portal, Yolo Roam Portal, API).

We do not knowingly collect more personal data than is necessary to provide our services.

3. How We Use Your Information

We use personal data to:

Provide, operate, and maintain our website, eSIMs, Yolo Roam, and carrier services

Create and manage reseller, partner, and portal accounts, and process API access

Process payments, invoices, and reseller bonus/commission calculations

Provide customer support, respond to inquiries, and handle complaints

Send service updates, account notices, and, where you have opted in, marketing communications about new solutions or partnership opportunities

Monitor network usage and traffic for billing, quality assurance, and troubleshooting

Detect, investigate, and prevent fraud, abuse, or unauthorized use of our services

Comply with legal, regulatory, and telecommunications obligations

Improve our website and services through aggregated or anonymized analytics

4. Legal Basis for Processing

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

Contract — to register accounts, deliver eSIMs and carrier services, and manage reseller and partner agreements

Legitimate interests — to secure our systems, prevent fraud, improve our services, and communicate with existing business contacts, balanced against your rights and interests

Consent — for optional marketing communications and non-essential cookies, which you may withdraw at any time

Legal obligation — to comply with telecommunications, tax, and consumer-protection laws

5. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

Enable core site functionality (strictly necessary cookies)

Understand how visitors use our site through analytics (e.g., page views, traffic sources)

Remember preferences and improve site performance

You can manage or disable non-essential cookies through your browser settings or, where available, our cookie consent banner. Disabling certain cookies may affect site functionality.

6. How We Share Your Information

We do not sell your personal data. We may share it with:

Telecom network and carrier partners — to activate and deliver eSIM, SMS, and voice services

Payment processors and financial institutions — to process payments, invoices, and reseller bonus payouts

IT, hosting, and portal service providers — to operate our website, API, and login portals

Business managers and resellers — limited data needed to fulfil orders or track performance

Professional advisors and regulators — where required for legal, tax, or compliance purposes

Law enforcement or courts — where required by law or to protect our rights, users, or the public

Any third party processing personal data on our behalf is bound by contractual obligations to protect it and use it only for the purposes we specify.

7. International Data Transfers

As a global telecom carrier serving airlines, OTAs, travel agencies, and mobile operators worldwide, we may transfer personal data outside the United Kingdom or European Economic Area, including to network partners and service providers in other countries.

Where we do, we rely on appropriate safeguards, such as the UK International Data Transfer Agreement or EU Standard Contractual Clauses, or transfer to jurisdictions recognized as providing adequate protection.

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, including to:

Provide ongoing services and support your account or reseller agreement

Meet tax, accounting, and telecommunications record-keeping obligations

Resolve disputes, complaints, or fraud investigations

Enforce our agreements

When personal data is no longer needed, we securely delete or anonymize it, subject to any legal retention requirements.

9. Data Security

We implement technical and organizational measures — including access controls, encryption in transit, and restricted portal access — designed to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you may have the right to:

Access the personal data we hold about you

Correct inaccurate or incomplete data

Request deletion of your data

Restrict or object to certain processing

Receive your data in a portable format

Withdraw consent at any time, where processing is based on consent

Lodge a complaint with your local data protection authority (in the UK, the Information Commissioner’s Office, ico.org.uk)

To exercise any of these rights, contact us using the details in Section 14. We may need to verify your identity before responding.

11. Children’s Privacy

Our website and services are intended for business use and are not directed at, or knowingly used by, individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can remove it.

12. Third-Party Links

Our website and communications may link to third-party sites and portals, including partner platforms, the SMS/Voice Portal, and the Yolo Roam Portal. This Policy does not apply to those third-party sites, and we encourage you to review their own privacy policies before providing personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Any changes will be posted on this page with a revised effective date. Your continued use of our website or services after changes are posted constitutes acceptance of the updated Policy.

14. Contact Information

If you have questions or concerns about this Privacy Policy or how we handle your personal data, please contact us at:

Xylen Management Ltd

Address — The Custard Factory, Zellig 206, Gibb Street, Birmingham B9 4AU, United Kingdom

Email — info@xylen.net