Privacy Policy
Last updated: November 12, 2026
1. Introduction
Vanguard AI Pte. Ltd. ("Vanguard", "we", "us", or "our") operates the Steady eSIMâ„¢ service at SteadyeSIM.com. We handle personal data in line with the Personal Data Protection Act 2012 of Singapore ("PDPA"), the Personal Data Protection Act 2010 of Malaysia ("Malaysia PDPA") for customers in Malaysia, and the EU General Data Protection Regulation ("GDPR") for visitors in the European Union and European Economic Area ("EU/EEA").
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.
- Which ad, partner link or campaign brought you to our site (for example an ad click identifier or campaign tags in the link), the page you landed on and the website that referred you, as described in Section 7.
3. How We Use Your Data
We use your personal data for the following purposes. Each purpose shows why we may use your data, which is also our legal basis where the GDPR applies:
- 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 how our website is used, in our own records, to improve our website and Services — necessary for our legitimate business interests.
- Complying with applicable legal and regulatory obligations — necessary for compliance with applicable law.
- Measuring which of our ads and partner links lead to visits and purchases, using tools from Google and Reddit (and Awin, where we use its affiliate programme) that run on our website, including by sending Google an encoded copy of your email address when you buy — only with your consent, given by choosing "Accept all" in our cookie banner. You can withdraw it at any time (see Section 7).
- Where we run an affiliate programme through Awin, reporting each sale to Awin so that partners who sent customers to us can be paid commission — necessary for our legitimate business interests (see Section 6).
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.
- Our own records of how our website is used are deleted after 26 months. Google Analytics keeps user-level and event-level data for the period set in our Google Analytics account, which is at most 14 months.
- 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.
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, the Malaysia PDPA and, if you are in the EU/EEA, the GDPR, you have the following rights:
- 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.
- If you are in Malaysia: the right to ask us to stop processing your personal data in a way that is likely to cause you substantial damage or distress, and to stop using it for direct marketing.
- If you are in the EU/EEA: the rights to restrict or object to our processing of your personal data, to receive it in a portable format, and to withdraw your consent at any time without affecting processing that took place before you withdrew it.
To exercise any of these rights, please contact us at support@steadyesim.com. We will respond within the time the law that applies to you allows: 21 days for access and correction requests under the Malaysia PDPA, one month under the GDPR, and otherwise within 30 days.
If you are unsatisfied with our response, you may complain to the data protection authority where you live: in Malaysia, the Personal Data Protection Commissioner; in the EU/EEA, your local data protection supervisory authority; in Singapore, the Personal Data Protection Commission 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 data protection authority where you live: in Malaysia, the Personal Data Protection Commissioner; in the EU/EEA, your local data protection supervisory authority; in Singapore, the Personal Data Protection Commission at pdpc.gov.sg.