Effective Date: 3/28/2025
Dejitech, Inc. dba Bcengi

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Dejitech, Inc. dba Bcengi (“Bcengi”) processes limited personal data on behalf of our customers in the course of providing eSIM and connectivity services. This page outlines how we handle that data in compliance with applicable data protection regulations such as the GDPR, UK GDPR, and CCPA.

1. Role of Bcengi as Data Processor
Bcengi acts as a data processor when providing eSIM provisioning and usage services to our customers, who are the data controllers. We process personal data only as instructed by the customer, and solely for the purposes of delivering and supporting the agreed-upon services.

2. Types of Personal Data Processed
The types of data we process typically include:

• Names or aliases
• Email addresses
• eSIM identifiers (e.g., EID, ICCID)
• Activation and usage metrics (e.g., timestamps, data volumes)

We do not require or process sensitive data such as government IDs, health information, or biometric data.

3. Data Subjects
The personal data we process may relate to our customers’ end-users, such as employees, travelers, guests, or resellers.

4. Purpose of Processing
We process personal data to:

• Deliver eSIM activation and data connectivity
• Maintain account functionality
• Provide customer support
• Monitor usage and system performance

We do not use customer data for advertising or behavioral profiling.

5. Sub-processors
To provide our services, we work with carefully selected sub-processors such as:

• Telecom infrastructure providers
• Cloud hosting providers
• Payment gateways
• Support platforms

Each sub-processor is contractually bound to handle data in accordance with applicable privacy laws and is subject to due diligence and security requirements.

6. International Data Transfers
If personal data is transferred outside the European Economic Area (EEA), United Kingdom, or other jurisdictions with data transfer restrictions, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Addendum
• Other approved legal mechanisms

7. Security Measures
Bcengi implements strong technical and organizational safeguards to protect data, including:

• Encryption of data in transit and at rest
• Role-based access controls
• Secure infrastructure policies
• Regular monitoring and vulnerability management

8. Data Retention
We retain personal data only for as long as necessary to provide our services and fulfill legal obligations. After that, we delete or anonymize the data unless retention is required by law.

9. Rights and Requests
If you are an end-user of a Bcengi customer and wish to exercise your rights (e.g., access, correction, deletion, objection), please contact the organization that provided your eSIM or account. Bcengi will assist our customers in fulfilling valid data subject requests as required by law.

10. Questions or Concerns
If you have questions about how Bcengi processes personal data as a processor, please contact us at: privacy@bcengi.com

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