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Privacy

Last updated: 2026-09-29·中文

This Privacy Policy explains how WEALTHY STAR INTERNATIONAL CAPITAL LIMITED, a company incorporated in Hong Kong and operating under the brand Panmigo ("Panmigo", "we", "us", or "our"), collects, uses, stores, discloses, transfers, and protects your personal information when you use our websites, mobile applications, eSIM services, and related services (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read this Privacy Policy.

1. Information We Collect

We may collect the following categories of information depending on how you use the Services.

1.1 Account and Contact Information

When you create an account, sign in, make a purchase, request support, or otherwise interact with us, we may collect:

  • Email address;
  • Account identifier;
  • Login and authentication information;
  • Information provided through Google Sign-In or Sign in with Apple, subject to your settings with those services;
  • Customer support communications;
  • Refund requests and related records;
  • Other information you voluntarily provide to us.

Certain information, such as an email address or authentication information, may be required to create and manage your Panmigo account or to provide particular Services. If required information is not provided, we may be unable to provide the relevant account feature or Service.

1.2 Order and eSIM Information

When you purchase or use an eSIM, we may collect information including:

  • Products and data plans purchased;
  • Order number and transaction status;
  • Purchase date and amount;
  • Destination country or region;
  • eSIM identifiers and provisioning information where necessary to provide the Service;
  • Installation status;
  • Activation status;
  • Data usage information;
  • Plan validity and expiration information;
  • Network and connectivity information required to operate, support, or troubleshoot the Service.

1.3 Payment Information

Payments may be processed by third-party payment service providers such as Stripe.

Panmigo does not normally store your complete payment card number, card security code, or equivalent sensitive payment credentials. Such information is generally processed directly by the relevant payment provider.

We may receive limited payment-related information, including:

  • Payment status;
  • Payment method type;
  • Transaction identifier;
  • Billing country or region;
  • Limited card information made available by the payment provider, such as the last digits of a payment card;
  • Refund information;
  • Chargeback or payment dispute information.

1.4 Device and Technical Information

When you access the Services, we may automatically collect technical information such as:

  • IP address;
  • Device type;
  • Browser type and version;
  • Operating system and version;
  • Device or app identifiers;
  • App version;
  • Language settings;
  • Currency settings;
  • Time zone;
  • Approximate location derived from an IP address;
  • Referring page or acquisition source;
  • Pages or screens viewed;
  • Interactions with the Services;
  • Error, diagnostic, crash, security, and performance information.

Panmigo does not collect precise GPS location for its standard eSIM purchasing and connectivity services.

If a future feature requires precise location information, we will request any permission required by the applicable operating system or law and update our disclosures where necessary.

1.5 Analytics and Usage Information

We may use analytics services, including Google Analytics and Firebase Analytics, to understand how users interact with Panmigo and to improve our Services.

Analytics and usage information may include:

  • Page or screen views;
  • Product views;
  • Country or plan selections;
  • Checkout activity;
  • Purchase events;
  • Installation and activation events;
  • App or website performance;
  • Traffic source;
  • Campaign information;
  • Feature usage;
  • Technical events required to measure service reliability.

We use analytics information for product operation, performance measurement, troubleshooting, security, and improvement of the Services.

2. How We Use Your Information

We may use personal information to:

  • Create and manage your Panmigo account;
  • Authenticate your identity;
  • Process orders and payments;
  • Provision and deliver eSIMs;
  • Provide installation and activation instructions;
  • Track the status and usage of your eSIM plan;
  • Provide customer support;
  • Process refund requests;
  • Investigate and resolve connectivity, installation, activation, account, or payment issues;
  • Detect and prevent fraud, abuse, unauthorized transactions, and security incidents;
  • Maintain and improve our websites, applications, products, and Services;
  • Analyze product performance and user experience;
  • Maintain service reliability and diagnose technical errors;
  • Send transactional communications relating to your account, purchase, eSIM, refund, security, or Service;
  • Send marketing communications where permitted by law and, where required, with your consent;
  • Maintain records required for accounting, tax, legal, or regulatory purposes;
  • Comply with applicable laws, regulations, court orders, and lawful requests;
  • Establish, exercise, or defend legal claims.

Where applicable law requires a legal basis for processing, we process personal information on one or more of the following bases:

  • Performance of a contract with you;
  • Compliance with a legal obligation;
  • Our legitimate interests, where permitted by law;
  • Your consent; or
  • Another lawful basis available under applicable law.

3. Cookies and Similar Technologies

Panmigo and our service providers may use cookies, software development kits ("SDKs"), pixels, local storage, and similar technologies to:

  • Keep you signed in;
  • Maintain website and application functionality;
  • Remember your preferences;
  • Maintain security;
  • Prevent fraud;
  • Measure performance;
  • Analyze traffic and usage;
  • Understand acquisition sources;
  • Support permitted marketing activities.

Where applicable law requires consent for non-essential cookies, SDKs, or similar technologies, we will obtain the required consent before using them.

You may manage cookies through your browser settings and, where available, through Panmigo's cookie or privacy controls.

Disabling certain cookies or technologies may affect the functionality of some parts of the Services.

4. How We Share Information

We do not disclose personal information except where reasonably necessary to provide, operate, protect, or improve the Services, comply with applicable law, or as otherwise described in this Privacy Policy.

4.1 eSIM and Telecommunications Partners

We may share necessary information with:

  • eSIM providers;
  • Mobile network operators;
  • Telecommunications partners;
  • Connectivity providers;
  • Provisioning platforms.

Such sharing may be necessary to provision, activate, operate, maintain, monitor, or troubleshoot your eSIM service.

4.2 Payment Providers

We may share transaction-related information with payment providers such as Stripe to:

  • Process payments;
  • Process refunds;
  • Handle disputes and chargebacks;
  • Perform fraud and security checks;
  • Meet applicable financial or regulatory requirements.

4.3 Authentication Providers

If you use Google Sign-In or Sign in with Apple, relevant information may be exchanged with Google or Apple to authenticate your account.

Your use of those authentication services is also subject to the applicable provider's privacy practices.

4.4 Analytics and Technology Providers

We may use third-party providers for services including:

  • Analytics;
  • Cloud hosting;
  • Data storage;
  • Security;
  • Authentication;
  • Customer support;
  • Email delivery;
  • Error monitoring;
  • Application infrastructure.

Such providers may process information on our behalf only as reasonably necessary to provide their services.

We require service providers that process personal information on our behalf to provide protections that are the same as or equivalent to those described in this Privacy Policy and required by applicable law, where such requirements apply.

4.5 Legal and Regulatory Disclosures

We may disclose personal information where reasonably necessary to:

  • Comply with applicable law or legal process;
  • Respond to lawful requests from courts, regulators, law-enforcement authorities, tax authorities, or government agencies;
  • Protect the rights, property, security, or safety of Panmigo, our users, or others;
  • Investigate fraud or security incidents;
  • Enforce our Terms of Service;
  • Establish, exercise, or defend legal claims.

4.6 Business Transfers

If Panmigo or its business is involved in a merger, acquisition, financing, restructuring, reorganization, sale of assets, or similar transaction, personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

5. International Data Transfers

Panmigo provides services internationally.

Our service providers, telecommunications partners, network operators, and technology providers may operate in countries or regions different from Hong Kong or from the country or region where you reside.

As a result, your personal information may be processed or stored outside Hong Kong or outside your country or region.

Where applicable law requires safeguards for an international transfer of personal information, we will take appropriate measures required by that law.

6. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, regulatory, security, accounting, tax, fraud-prevention, and dispute-resolution purposes.

Retention periods vary depending on the nature of the information and applicable legal requirements.

6.1 Account Information

Account information is generally retained while your Panmigo account remains active.

If you delete your account, personal information associated with the account will be deleted or anonymized within a reasonable period, except for information that we are required or permitted to retain for legitimate legal, regulatory, tax, accounting, fraud-prevention, security, dispute-resolution, or enforcement purposes.

6.2 Transaction and Business Records

Order, payment, invoice, refund, transaction, and accounting records may be retained for the period required by applicable law.

Certain business records relating to income, expenditure, payments, invoices, receipts, and transactions may be retained for at least seven years where required under applicable Hong Kong tax or accounting laws.

6.3 Customer Support and Technical Records

Customer support communications, technical logs, security records, and diagnostic information may be retained for as long as reasonably necessary to:

  • Resolve support issues;
  • Maintain security;
  • Prevent fraud and abuse;
  • Investigate disputes;
  • Improve service reliability;
  • Comply with legal obligations.

6.4 Analytics Information

Analytics information is retained only for as long as reasonably necessary for analytics, product improvement, security, and operational purposes, subject to the retention settings and controls available through the relevant analytics provider.

6.5 Backups

Deleted information may remain temporarily in encrypted or restricted backup systems before being overwritten or securely deleted in accordance with our backup and retention processes.

When personal information is no longer reasonably required, we will delete, anonymize, or otherwise securely dispose of it as appropriate.

7. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against:

  • Unauthorized access;
  • Loss;
  • Misuse;
  • Alteration;
  • Unauthorized disclosure;
  • Destruction.

However, no internet transmission, electronic storage system, telecommunications network, or information security system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should notify us promptly if you believe your account has been compromised.

8. Your Privacy Rights

Depending on where you live and the applicable law, you may have rights concerning your personal information, including the right to:

  • Request access to personal information we hold about you;
  • Request correction of inaccurate or incomplete information;
  • Request deletion of personal information;
  • Request restriction of certain processing;
  • Object to certain processing;
  • Withdraw consent where processing is based on consent;
  • Request data portability where applicable;
  • Opt out of certain marketing communications;
  • Lodge a complaint with an applicable data protection authority.

Under Hong Kong's Personal Data (Privacy) Ordinance, eligible individuals may request access to and correction of their personal data, subject to applicable legal requirements and exceptions.

To exercise a privacy right, contact support@panmigo.com.

We may need to verify your identity before completing certain requests.

9. Account and Data Deletion

You may request deletion of your Panmigo account and personal information associated with that account.

Where available, you may initiate account deletion:

  • Through the account settings in the Panmigo mobile application; or
  • Through Panmigo's designated account-deletion page on our website.

If necessary, you may also contact support@panmigo.com for assistance relating to an account-deletion request.

Account deletion is permanent and may result in loss of access to:

  • Your Panmigo account;
  • eSIM information associated solely with that account;
  • Account preferences;
  • Other account-linked features.

When an account is deleted, we will delete or anonymize personal information associated with the account unless retention is reasonably necessary or required for purposes including:

  • Tax and accounting compliance;
  • Legal or regulatory obligations;
  • Payment disputes and chargebacks;
  • Fraud prevention;
  • Security;
  • Enforcement of legal rights;
  • Resolution of disputes.

Deleting your Panmigo account does not require us to delete information that applicable law requires or permits us to retain.

Where technically and legally applicable, we may also revoke, disconnect, or otherwise invalidate authentication credentials associated with supported third-party sign-in services as part of the account-deletion process.

10. Marketing Communications

Where permitted by law, Panmigo may send promotional emails or other marketing communications.

Where consent is required, we will obtain the appropriate consent before using your personal information for direct marketing.

You may unsubscribe from marketing communications at any time by:

  • Using the unsubscribe mechanism included in the communication; or
  • Contacting us at support@panmigo.com.

Transactional communications concerning purchases, account security, eSIM delivery, installation, activation, service notices, or refunds are not marketing communications and may continue even if you opt out of marketing communications.

11. Sale or Sharing of Personal Information

Panmigo does not sell personal information for monetary consideration.

If the use of a particular advertising, analytics, or similar technology is legally treated as a "sale", "sharing", or equivalent activity under an applicable privacy law, we will provide any notices, choices, or opt-out mechanisms required by that law.

12. Children's Privacy

The Services are intended for individuals who are at least 18 years old or who have reached the legal age required to enter into a contract in their jurisdiction.

If an individual below the applicable legal age uses the Services, the purchase and use of the Services must be made or authorized by a parent or legal guardian where required by law.

We do not knowingly collect personal information from children in violation of applicable law.

If you believe that a child has provided personal information to us in circumstances that violate applicable law, please contact us at support@panmigo.com.

13. Third-Party Websites and Services

The Services may contain links to, depend on, or integrate with third-party websites, applications, platforms, or services.

Panmigo is not responsible for the independent privacy practices of third parties.

We encourage you to review the privacy policies of relevant third parties before providing personal information to them.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • Our Services;
  • Business practices;
  • Technology;
  • Service providers;
  • Legal or regulatory requirements.

When required by applicable law, we will provide appropriate notice of material changes.

The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised.

15. Contact Us

For questions, privacy requests, complaints, or account and data deletion matters, contact:

  • Company name: WEALTHY STAR INTERNATIONAL CAPITAL LIMITED
  • Operating brand: Panmigo
  • Registration No.: 66796344-000-10-25-7
  • Registered in: Hong Kong
  • Registered address: FLAT D 22/F YHC TOWER, 1 SHEUNG YUET ROAD, KOWLOON BAY, KL
  • Email: support@panmigo.com
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