Privacy Policy

Last updated: May 14, 2026

1. Introduction

Vanguard AI Pte. Ltd. ("Vanguard", "we", "us", or "our") operates the Steady eSIM service at SteadyeSIM.com. We are committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA").

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in relation to it. By using our Services you consent to the practices described in this policy.

2. Data We Collect

We collect the following categories of personal data when you use our Services:

2.1 Information You Provide Directly

  • Email address provided at checkout for eSIM QR code delivery and order confirmation.
  • Name and billing address where required by our payment processor for transaction processing.
  • Payment information including card details or PayNow reference, processed and held securely by Stripe. Vanguard does not store raw card data at any point.
  • Communications you send to us via email or our support channels.

2.2 Information Collected Automatically

  • Device information including device type, operating system, and eSIM compatibility data where relevant to service delivery.
  • Browser type, IP address, and general geographic location derived from IP.
  • Usage data including pages visited, time spent on site, and actions taken during the checkout flow.
  • Cookie and tracking data as described in Section 7 of this policy.

3. How We Use Your Data

We use your personal data for the following purposes and on the following legal bases under the PDPA:

  • Delivering your eSIM QR code and order confirmation to your email address — necessary for the performance of your purchase contract.
  • Processing payments securely via Stripe — necessary for the performance of your purchase contract.
  • Sending transactional communications including receipts, order confirmations, and support responses — necessary for the performance of your purchase contract.
  • Detecting and preventing fraud, abuse, and unauthorised access — necessary for our legitimate business interests and legal obligations.
  • Analysing usage trends and improving our website and Services — necessary for our legitimate business interests.
  • Complying with applicable legal and regulatory obligations — necessary for compliance with applicable law.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Marketing Communications

We do not send marketing emails without your explicit consent. If you opt in to marketing communications at any point, you may withdraw that consent at any time by clicking the unsubscribe link in any marketing email or by contacting us directly at support@steadyesim.com.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

  • Order and transaction records including email address and purchase details are retained for seven years from the date of transaction in accordance with Singapore's accounting and tax obligations.
  • Support communications are retained for two years from the date of the last communication.
  • Website usage and analytics data is retained for a maximum of 26 months in line with standard analytics practice.
  • Cookie data is retained in accordance with the individual cookie lifespans set out in Section 7.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

6. Sharing Your Data

We do not sell, rent, or trade your personal data to third parties. We share personal data only in the following circumstances:

  • Stripe — our payment processor — receives billing and payment data necessary to process your transaction. Stripe's privacy policy is available at stripe.com/privacy.
  • eSIM infrastructure providers — your email address and order reference may be shared with our upstream eSIM provider solely for the purpose of generating and delivering your eSIM profile.
  • Google Analytics and Google Ads — anonymised usage and conversion data is shared with Google for analytics and advertising performance measurement purposes. No personally identifiable information is shared with Google.
  • Legal and regulatory authorities — we may disclose personal data where required to do so by law, court order, or at the request of a competent regulatory authority in Singapore.

All third-party service providers are contractually required to process your data only for the purposes for which it was shared and to maintain appropriate security standards.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on SteadyeSIM.com for the following purposes:

  • Essential cookies are required for the website and checkout to function correctly. These cannot be disabled.
  • Analytics cookies allow us to understand how visitors interact with our site using tools including Google Analytics. These cookies collect anonymised data and do not identify you personally.
  • Advertising cookies are used to measure the performance of our Google Ads campaigns and to attribute conversions. These cookies do not build personal advertising profiles.

You may disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the checkout process.

8. Data Security

Vanguard implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include industry-standard TLS encryption for all data in transit, secure third-party payment processing via Stripe, and restricted internal access to personal data on a need-to-know basis.

No method of transmission over the internet is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security.

9. Your Rights Under the PDPA

As a user based in Singapore, you have the following rights under the Personal Data Protection Act 2012:

  • The right to access personal data we hold about you.
  • The right to correct any inaccurate or incomplete personal data we hold about you.
  • The right to withdraw consent to the collection, use, or disclosure of your personal data, subject to legal or contractual restrictions.
  • The right to request the deletion of personal data we hold about you, subject to our legal retention obligations.

To exercise any of these rights, please contact us at support@steadyesim.com. We will respond to all valid requests within 30 days.

If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore at pdpc.gov.sg.

10. Children's Privacy

Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us at support@steadyesim.com and we will take steps to delete it promptly.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting the updated policy on SteadyeSIM.com with a revised "Last updated" date. Your continued use of the Services after any update constitutes your acceptance of the revised policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Vanguard AI Pte. Ltd.

Email: support@steadyesim.com

For complaints that cannot be resolved directly with us, you may contact the Personal Data Protection Commission of Singapore at pdpc.gov.sg.